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 High Court addressed the extension of due dates u/s 73 of the CGST/AGST Act, 2017 due to the Covid-19 pandemic. It examined the provisions related to the time limit prescribed u/s 73 and the invocation of Section 168A, considering the "force majeure" condition. The Court observed that, notwithstanding Section 16(4), for financial years 2017-18 to 2020-21, the registered person shall be entitled to take input tax credit in any return filed u/s 39 up to November 30, 2021. The amendments brought by the Finance (No. 2) Act, 2024, rendered the challenge in the writ petition redundant. The petitioner is entitled to avail the input tax credit benefit for the relevant period, subject to the conditions prescribed in the newly inserted Sections 16(5) and 16(6). Consequently, the impugned order was set aside, and the matter was remanded to the competent jurisdictional officer for appropriate orders.
The High Court addressed the extension of due dates u/s 73 of the CGST/AGST Act, 2017 due to the Covid-19 pandemic. It examined the provisions related to the time limit prescribed u/s 73 and the invocation of Section 168A, considering the "force majeure" condition. The Court observed that, notwithstanding Section 16(4), for financial years 2017-18 to 2020-21, the registered person shall be entitled to take input tax credit in any return filed u/s 39 up to November 30, 2021. The amendments brought by the Finance (No. 2) Act, 2024, rendered the challenge in the writ petition redundant. The petitioner is entitled to avail the input tax credit benefit for the relevant period, subject to the conditions prescribed in the newly inserted Sections 16(5) and 16(6). Consequently, the impugned order was set aside, and the matter was remanded to the competent jurisdictional officer for appropriate orders.
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