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...
Levy of penalty u/s 129(5) of GST Act for discrepancy between PIN code of petitioner in Tax Invoices and E-Way Bill. Court held minor discrepancy in PIN code in GST Registration and Tax Invoices as minor violation of GST enactments. Difference in address in E-Way Bill and Tax Invoices due to Head Office and actual dispatch place. Petitioner earlier obtained VAT registration for dispatch place. Tax Invoices raised from same address. Imposition of penalty for technical breach or minor address variance in Tax Invoices and E-Way Bill unjustified u/s 129(5). GST enactments aim to avoid unjust tax burden on assessee regularly paying tax and complying with law. Impugned order quashed. Respondent directed to refund amount paid or allow credit adjustment towards future tax liability.
Levy of penalty u/s 129(5) of GST Act for discrepancy between PIN code of petitioner in Tax Invoices and E-Way Bill. Court held minor discrepancy in PIN code in GST Registration and Tax Invoices as minor violation of GST enactments. Difference in address in E-Way Bill and Tax Invoices due to Head Office and actual dispatch place. Petitioner earlier obtained VAT registration for dispatch place. Tax Invoices raised from same address. Imposition of penalty for technical breach or minor address variance in Tax Invoices and E-Way Bill unjustified u/s 129(5). GST enactments aim to avoid unjust tax burden on assessee regularly paying tax and complying with law. Impugned order quashed. Respondent directed to refund amount paid or allow credit adjustment towards future tax liability.
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