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 held that the negative blocking of the Electronic Credit Ledger (ECL) of the writ petitioner by the respondents, purportedly exercising powers u/r 86A of the Central Goods and Services Tax Rules, 2017, cannot be sustained. The issue of negative blocking stands conclusively decided in favor of the writ petitioner in light of the judgment in Best Crop Science Pvt. Ltd. v. Principal Commissioner, where it was held that orders disallowing debit from the ECL in excess of the available Input Tax Credit at the time of passing such orders (referred to as Negative blocking) are set aside. Consequently, the petition was allowed.
The High Court held that the negative blocking of the Electronic Credit Ledger (ECL) of the writ petitioner by the respondents, purportedly exercising powers u/r 86A of the Central Goods and Services Tax Rules, 2017, cannot be sustained. The issue of negative blocking stands conclusively decided in favor of the writ petitioner in light of the judgment in Best Crop Science Pvt. Ltd. v. Principal Commissioner, where it was held that orders disallowing debit from the ECL in excess of the available Input Tax Credit at the time of passing such orders (referred to as Negative blocking) are set aside. Consequently, the petition was allowed.
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