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 High Court set aside the impugned assessment order that disallowed Input Tax Credit solely on the ground of delay u/s 16(4) of the GST Acts. The Court directed the assessing authority to re-do the assessment considering the amendment and reconsider the petitioner's submissions on three other issues: ineligibility u/s 17(5), ineligible ITC declaration, and excess ITC claimed due to outward supplies not supported by E-way bills and discrepancies between GSTR-9 and GSTR-1. The petitioner was granted four weeks to file objections on all issues, including Section 16(4). The petition was disposed of accordingly.
The High Court set aside the impugned assessment order that disallowed Input Tax Credit solely on the ground of delay u/s 16(4) of the GST Acts. The Court directed the assessing authority to re-do the assessment considering the amendment and reconsider the petitioner's submissions on three other issues: ineligibility u/s 17(5), ineligible ITC declaration, and excess ITC claimed due to outward supplies not supported by E-way bills and discrepancies between GSTR-9 and GSTR-1. The petitioner was granted four weeks to file objections on all issues, including Section 16(4). The petition was disposed of accordingly.
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