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...
ITC availed in excess of credit reflected in GSTR-2A, mismatch between GSTR-3B and GSTR-2A, ITC not reversed based on GSTR-2A debit, non-generation of e-way bill. Petitioner seeks opportunity to explain discrepancies, invoking principles of natural justice. High Court set aside impugned order, directed petitioner to deposit 25% of disputed tax after adjusting Rs. 1,00,000 already paid within 4 weeks to lift bank attachment. Impugned assessment order treated as show cause notice, petitioner to file objections with supporting documents within 4 weeks. Respondent to consider objections after providing reasonable opportunity of hearing and pass orders in accordance with law. Writ Petition disposed of.
ITC availed in excess of credit reflected in GSTR-2A, mismatch between GSTR-3B and GSTR-2A, ITC not reversed based on GSTR-2A debit, non-generation of e-way bill. Petitioner seeks opportunity to explain discrepancies, invoking principles of natural justice. High Court set aside impugned order, directed petitioner to deposit 25% of disputed tax after adjusting Rs. 1,00,000 already paid within 4 weeks to lift bank attachment. Impugned assessment order treated as show cause notice, petitioner to file objections with supporting documents within 4 weeks. Respondent to consider objections after providing reasonable opportunity of hearing and pass orders in accordance with law. Writ Petition disposed of.
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