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...
Challenge to order u/s 62 of GST Act, 2017 - petitioner's case of being a small dealer who failed to notice the order. Held that rigors of sub-section 2 to Section 62 need not be pressed as Department's intention is to ensure statutory compliance if dealer complies and pays late fee charges. Delay in filing GSTR 3B on 30.05.2024 beyond 30 days from impugned order dated 30.01.2024 deemed condoned. Petitioner to pay late fee u/s 47. Respondent may independently assess returns and initiate proceedings for any tax shortfall under GST Act, 2017. Petition disposed of.
Challenge to order u/s 62 of GST Act, 2017 - petitioner's case of being a small dealer who failed to notice the order. Held that rigors of sub-section 2 to Section 62 need not be pressed as Department's intention is to ensure statutory compliance if dealer complies and pays late fee charges. Delay in filing GSTR 3B on 30.05.2024 beyond 30 days from impugned order dated 30.01.2024 deemed condoned. Petitioner to pay late fee u/s 47. Respondent may independently assess returns and initiate proceedings for any tax shortfall under GST Act, 2017. Petition disposed of.
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