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...
The petitioners' belated input tax credit denial u/s 16(4) of GST Acts overturned by High Court. Orders set aside, cases remitted to Assessing Officer for fresh decision as per Finance Act, 2024. If proposals in Finance Bill, 2024 are enacted, petitioners may benefit. Petitioners to deposit 25% disputed tax, excluding input tax credit denial, for orders on merits. Petition disposed off.
The petitioners' belated input tax credit denial u/s 16(4) of GST Acts overturned by High Court. Orders set aside, cases remitted to Assessing Officer for fresh decision as per Finance Act, 2024. If proposals in Finance Bill, 2024 are enacted, petitioners may benefit. Petitioners to deposit 25% disputed tax, excluding input tax credit denial, for orders on merits. Petition disposed off.
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