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...
Inadvertent human error in filing a return led to denial of input tax credit (ITC) claim due to incorrect GSTIN number. The digital platform foreclosed the remedy to rectify the error due to passage of time. The court held that the denial was a bona fide mistake, and the IDA who deducted and paid the tax was made a party. Refund denial could lead to the petitioner's company closing down, considering the huge refund amount. The court directed the respondent authorities to facilitate opening the portal for a limited period or allow manual rectification upon the petitioner's representation, as this is a peculiar and special circumstance. The assessing officer can verify the specific deductions claimed with the returns filed by the IDA. The petition was allowed.
Inadvertent human error in filing a return led to denial of input tax credit (ITC) claim due to incorrect GSTIN number. The digital platform foreclosed the remedy to rectify the error due to passage of time. The court held that the denial was a bona fide mistake, and the IDA who deducted and paid the tax was made a party. Refund denial could lead to the petitioner's company closing down, considering the huge refund amount. The court directed the respondent authorities to facilitate opening the portal for a limited period or allow manual rectification upon the petitioner's representation, as this is a peculiar and special circumstance. The assessing officer can verify the specific deductions claimed with the returns filed by the IDA. The petition was allowed.
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