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 challenged denial of input tax credit (ITC) on manpower supply services received during 2017-18 to 2022-23, citing Circular No. 211/5/2024-GST. Court held petitioner entitled to ITC and cannot be deprived or liable for interest due to belated claim, as per circular. Circular supports petitioner's claim, binding on respondents as per KP Varghese judgment. However, as circular issued during pendency, respondent didn't have its benefit earlier. Petition disposed, directing respondent to consider petitioner's objections within three weeks, bearing in mind circular and pass orders accordingly. Petitioner granted liberty to file objections to show cause notice.
Petitioner challenged denial of input tax credit (ITC) on manpower supply services received during 2017-18 to 2022-23, citing Circular No. 211/5/2024-GST. Court held petitioner entitled to ITC and cannot be deprived or liable for interest due to belated claim, as per circular. Circular supports petitioner's claim, binding on respondents as per KP Varghese judgment. However, as circular issued during pendency, respondent didn't have its benefit earlier. Petition disposed, directing respondent to consider petitioner's objections within three weeks, bearing in mind circular and pass orders accordingly. Petitioner granted liberty to file objections to show cause notice.
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