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 held that the appellant's case has to be accepted and necessary rectification has to be done. Due to discrepancies in data migration from the Legacy ACES Application to the new Integrated ACES-GST Application, the appellant's tax liabilities were affected as PART B of the revised return was not duly populated. The impugned order was set aside with a direction to the authorities to make the necessary correction in the Portal and issue a revised order accepting the appellant's stand. The appeal was allowed.
The HC held that the appellant's case has to be accepted and necessary rectification has to be done. Due to discrepancies in data migration from the Legacy ACES Application to the new Integrated ACES-GST Application, the appellant's tax liabilities were affected as PART B of the revised return was not duly populated. The impugned order was set aside with a direction to the authorities to make the necessary correction in the Portal and issue a revised order accepting the appellant's stand. The appeal was allowed.
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