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 failed to reflect the remittance of Goods and Services Tax (GST) in their GSTR returns due to technical reasons, and there was a lack of clear proof of payment of consideration and tax towards the inward supply. The court granted liberty to the petitioners to claim the benefit of the relevant circulars, namely, Circular No. 183/15/2022-GST dated 27.12.2022 and Circular No. 193/05/2023-GST dated 17.07.2023, within one month before the appropriate authority. The authority shall examine the claim of the individual dealer and process the claim accordingly, following the reasoning, observations, and conclusions recorded in the cited judgment and connected matters.
The petitioners failed to reflect the remittance of Goods and Services Tax (GST) in their GSTR returns due to technical reasons, and there was a lack of clear proof of payment of consideration and tax towards the inward supply. The court granted liberty to the petitioners to claim the benefit of the relevant circulars, namely, Circular No. 183/15/2022-GST dated 27.12.2022 and Circular No. 193/05/2023-GST dated 17.07.2023, within one month before the appropriate authority. The authority shall examine the claim of the individual dealer and process the claim accordingly, following the reasoning, observations, and conclusions recorded in the cited judgment and connected matters.
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