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 was entitled to a refund of Rs. 53,08,494/- which was paid in excess along with the return in Form GSTR-3B for the month of March 2023. The excess payment arose due to rectification of an error committed while filing the return for January 2023, wherein the reverse charge liability was not reflected separately and was clubbed with the output tax liability. The High Court allowed the petition, holding that the petitioner had rightly rectified the error in the March 2023 return by paying the excess amount through the electronic cash ledger, and was entitled to the refund claimed, in view of the Circular No. 26/2017 and the facts of the case.
The petitioner was entitled to a refund of Rs. 53,08,494/- which was paid in excess along with the return in Form GSTR-3B for the month of March 2023. The excess payment arose due to rectification of an error committed while filing the return for January 2023, wherein the reverse charge liability was not reflected separately and was clubbed with the output tax liability. The High Court allowed the petition, holding that the petitioner had rightly rectified the error in the March 2023 return by paying the excess amount through the electronic cash ledger, and was entitled to the refund claimed, in view of the Circular No. 26/2017 and the facts of the case.
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