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...
Petitioner challenged order u/s 74 of TNGST Act, 2017 for assessment year 2017-18 due to mismatch between GSTR 3B and auto-populated GSTR 2A regarding input tax credit. Court held that respondent failed to consider changes in CGST Rules, 2017, particularly Rule 36(4). Difference between GSTR 2A and GSTR 3B attributable to mismatch for supplies by RAMCO, constituting 10.53% of total credit, less than 20% as per amended Rule 36(4) till 09.10.2019. Impugned order set aside, case remitted to respondent to pass fresh orders considering amended provisions under Notification No. 49/2019-Central Tax. Recovery proceedings kept in abeyance pending remand orders. Petition allowed by way of remand.
Petitioner challenged order u/s 74 of TNGST Act, 2017 for assessment year 2017-18 due to mismatch between GSTR 3B and auto-populated GSTR 2A regarding input tax credit. Court held that respondent failed to consider changes in CGST Rules, 2017, particularly Rule 36(4). Difference between GSTR 2A and GSTR 3B attributable to mismatch for supplies by RAMCO, constituting 10.53% of total credit, less than 20% as per amended Rule 36(4) till 09.10.2019. Impugned order set aside, case remitted to respondent to pass fresh orders considering amended provisions under Notification No. 49/2019-Central Tax. Recovery proceedings kept in abeyance pending remand orders. Petition allowed by way of remand.
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