Transfer pricing requires evidence for AMP transactions, functionally reliable comparables, and appropriate aggregation or Berry Ratio benchmarking me...
Revisionary jurisdiction cannot reopen share capital assessments where adequate inquiry supports a permissible view and no independent error is establ...
Reassessment jurisdiction fails where unverified portal information is aggregated without examining the taxpayer's explanation or relevance of entries...
Statutory sanction for delayed reassessment requires approval from the prescribed authority; approval by an inferior authority invalidates jurisdictio...
Transfer pricing margin adjustments require matching treatment of non-operating income and related costs, with comparability issues reconsidered on ev...
Preliminary-expense amortisation and MAT exempt-income adjustments prevailed, while trademark costs and managerial remuneration require fresh verifica...
Export valuation requires contemporaneous evidence; unrelated invoices cannot prove overvaluation, and dual penalties on firm and partner are impermis...
Advance Ruling application on maintainability - Reversal of input tax credit to extent of tax element in credit note - no agreement between parties on credit notes not treated as financial/commercial credit notes - no agreement to reduce ITC claim - mismatch of ITC claim figures between GSTR-3B and GSTR-2A - impact of incorrect output tax liability reduction based on credit note issued. Questions on ITC reversal based on credit notes and eligibility to claim ITC based on original invoices admissible u/s 97(2)(d) of CGST Act. Questions on ITC rejection due to GSTR-3B and GSTR-2A mismatch and impact of supplier's incorrect output tax liability reduction on applicant's ITC not covered u/s 97(2). Applicant issued notice u/s 61 for discrepancies, advance ruling filed later. Proceedings pending against applicant, application liable to be rejected u/s 98(2) first proviso.
Advance Ruling application on maintainability - Reversal of input tax credit to extent of tax element in credit note - no agreement between parties on credit notes not treated as financial/commercial credit notes - no agreement to reduce ITC claim - mismatch of ITC claim figures between GSTR-3B and GSTR-2A - impact of incorrect output tax liability reduction based on credit note issued. Questions on ITC reversal based on credit notes and eligibility to claim ITC based on original invoices admissible u/s 97(2)(d) of CGST Act. Questions on ITC rejection due to GSTR-3B and GSTR-2A mismatch and impact of supplier's incorrect output tax liability reduction on applicant's ITC not covered u/s 97(2). Applicant issued notice u/s 61 for discrepancies, advance ruling filed later. Proceedings pending against applicant, application liable to be rejected u/s 98(2) first proviso.
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