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 failed to substantiate Input Tax Credit claim due to lack of supplier certificates. Discrepancy noted between Input Tax Credit availed in GSTR 3B and auto-populated in GSTR 2A. Electronic Credit Ledger balance after adjustment indicates inadequate explanation. Petitioner's credit tax position appears incorrect, unable to avail claimed IGST amount under CGST and SGST credit. Court grants temporary relief, staying recovery proceedings for three months, allowing petitioner to file revision petition u/s 161 within 30 days. Petition disposed.
Petitioner failed to substantiate Input Tax Credit claim due to lack of supplier certificates. Discrepancy noted between Input Tax Credit availed in GSTR 3B and auto-populated in GSTR 2A. Electronic Credit Ledger balance after adjustment indicates inadequate explanation. Petitioner's credit tax position appears incorrect, unable to avail claimed IGST amount under CGST and SGST credit. Court grants temporary relief, staying recovery proceedings for three months, allowing petitioner to file revision petition u/s 161 within 30 days. Petition disposed.
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