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...
Maintainability of petition - availability of alternative remedy - transitional credit - no bar for filing return in GST portal of Telangana where petitioner's branch exists - Section 140 entitles registered person to take CENVAT credit in electronic credit ledger - petitioner's registration number/PAN same nationwide - last proviso to Section 140(8) allows credit transfer to any registered person with same PAN for centralized registration under existing law - filing return in Telangana GST portal and credit transfer permissible u/s 140(8) proviso - assumption of return filing restriction unfounded - impugned action based on flawed notion - petition allowed.
Maintainability of petition - availability of alternative remedy - transitional credit - no bar for filing return in GST portal of Telangana where petitioner's branch exists - Section 140 entitles registered person to take CENVAT credit in electronic credit ledger - petitioner's registration number/PAN same nationwide - last proviso to Section 140(8) allows credit transfer to any registered person with same PAN for centralized registration under existing law - filing return in Telangana GST portal and credit transfer permissible u/s 140(8) proviso - assumption of return filing restriction unfounded - impugned action based on flawed notion - petition allowed.
Note: It is a system-generated summary and is for quick reference only.