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...
HC allowed the petition by remanding the matter to the Adjudicating Authority. The alleged violation of Section 16(4) of the CGST Act by the petitioners for not complying with input tax credit provisions would no longer exist due to the insertion of Section 16(5). The Adjudicating Authority is directed to pass a fresh de novo order considering Section 16(5), which came into operation on 01.07.2017, after verifying the facts.
HC allowed the petition by remanding the matter to the Adjudicating Authority. The alleged violation of Section 16(4) of the CGST Act by the petitioners for not complying with input tax credit provisions would no longer exist due to the insertion of Section 16(5). The Adjudicating Authority is directed to pass a fresh de novo order considering Section 16(5), which came into operation on 01.07.2017, after verifying the facts.
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