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 HC dismissed the writ petition challenging the validity of the show cause notice (SCN) issued u/ss 74 and 122 of the CGST Act, 2017. The SCN was issued for generating fake input tax credit (ITC) through circular trading by multiple firms from 2017 to 2022. The HC held that joint assessment proceedings u/s 74 against all involved firms were justified, and the petitioner could not be singled out. The SCN was validly issued within the limitation period specified in Sections 74(2) and 74(10) of the CGST Act.
The HC dismissed the writ petition challenging the validity of the show cause notice (SCN) issued u/ss 74 and 122 of the CGST Act, 2017. The SCN was issued for generating fake input tax credit (ITC) through circular trading by multiple firms from 2017 to 2022. The HC held that joint assessment proceedings u/s 74 against all involved firms were justified, and the petitioner could not be singled out. The SCN was validly issued within the limitation period specified in Sections 74(2) and 74(10) of the CGST Act.
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