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 allowed the writ petition and set aside the impugned order. The matter was remitted back to the respondent authority to pass a fresh order on merits in accordance with the statutory amendment of Section 16(5) of the CGST Act, 2017. Section 16(5) permits belated availing of input tax credit for the assessment years 2017-2018 to 2020-2021, which was notified by the Central Government vide Notification No. 22/2024-Central Tax dated 08.10.2024. The Court held that the Parliament has extended an olive branch to taxpayers by inserting Section 16(5) to address the issue of delayed availing of input tax credit.
The High Court allowed the writ petition and set aside the impugned order. The matter was remitted back to the respondent authority to pass a fresh order on merits in accordance with the statutory amendment of Section 16(5) of the CGST Act, 2017. Section 16(5) permits belated availing of input tax credit for the assessment years 2017-2018 to 2020-2021, which was notified by the Central Government vide Notification No. 22/2024-Central Tax dated 08.10.2024. The Court held that the Parliament has extended an olive branch to taxpayers by inserting Section 16(5) to address the issue of delayed availing of input tax credit.
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