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...
Classification dispute regarding Geo Membrane manufactured by petitioner - whether to be classified under Chapter 59 or Chapter 39 of Tariff. Court relied on Coordinate Bench decision in MESSERS CTM TECHNICAL TEXTILES LTD case, holding product falls under Chapter 59, not Chapter 39 as ruled by Gujarat Advance Ruling Authority. Petitioner liable to pay GST at 12% from 15.11.2017 under HSN Code 59111000, not 18%. Respondent authority directed to apply discounted 12% GST rate on petitioner's product. Petition allowed.
Classification dispute regarding Geo Membrane manufactured by petitioner - whether to be classified under Chapter 59 or Chapter 39 of Tariff. Court relied on Coordinate Bench decision in MESSERS CTM TECHNICAL TEXTILES LTD case, holding product falls under Chapter 59, not Chapter 39 as ruled by Gujarat Advance Ruling Authority. Petitioner liable to pay GST at 12% from 15.11.2017 under HSN Code 59111000, not 18%. Respondent authority directed to apply discounted 12% GST rate on petitioner's product. Petition allowed.
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