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...
Demand on account of alleged delay in availing Input Tax Credit purportedly Rs. 23,35,892/- out of Rs. 57,12,114/-. Impugned order set aside to that extent, case remitted to consider proposals in GST Council's 53rd Meeting and Finance (No.2) Bill, 2024 (Bill No.55 of 2024) Clause 114 & 146. For balance amount Rs. 33,76,222/-, petitioner given liberty to file statutory appeal within 30 days. Petition disposed.
Demand on account of alleged delay in availing Input Tax Credit purportedly Rs. 23,35,892/- out of Rs. 57,12,114/-. Impugned order set aside to that extent, case remitted to consider proposals in GST Council's 53rd Meeting and Finance (No.2) Bill, 2024 (Bill No.55 of 2024) Clause 114 & 146. For balance amount Rs. 33,76,222/-, petitioner given liberty to file statutory appeal within 30 days. Petition disposed.
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