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 petitioner had unutilized Input Tax Credit (ITC) of Rs.2,42,15,906/- under the VAT Act for the period from 1st April 2017 to 30th June 2017, which was carried forward to the GST regime by filing Form GST TRAN 1. Subsequently, the petitioner reversed the ITC in the Electronic Credit Ledger by filing Form DRC-03. The High Court, relying on its previous decision in R. N. Laboratories Pvt. Ltd., directed the respondent authorities to process the petitioner's application for refund of Rs.2,42,15,906/- along with statutory interest payable u/s 38 of the VAT Act, as the petitioner had not availed any credit amount carried forward to GST. The authorities were directed to complete the exercise within 12 weeks from the date of receipt of the order.
The petitioner had unutilized Input Tax Credit (ITC) of Rs.2,42,15,906/- under the VAT Act for the period from 1st April 2017 to 30th June 2017, which was carried forward to the GST regime by filing Form GST TRAN 1. Subsequently, the petitioner reversed the ITC in the Electronic Credit Ledger by filing Form DRC-03. The High Court, relying on its previous decision in R. N. Laboratories Pvt. Ltd., directed the respondent authorities to process the petitioner's application for refund of Rs.2,42,15,906/- along with statutory interest payable u/s 38 of the VAT Act, as the petitioner had not availed any credit amount carried forward to GST. The authorities were directed to complete the exercise within 12 weeks from the date of receipt of the order.
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