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 set aside adjudication order u/s 74(9) of WBGST/CGST Act 2017 and remanded for fresh consideration. The adjudicating authority failed to address key submissions regarding input tax credit claims against supplies from deregistered vendors, particularly concerning retrospective cancellation of supplier registrations and proof of goods movement. The court found procedural deficiencies as the assessing officer did not record findings on precedents cited by assessee. Matter remanded for fresh adjudication with directions to consider all factual issues, legal principles, and grant personal hearing. Appellant permitted to submit fresh reply with supporting documentation and judicial precedents.
HC set aside adjudication order u/s 74(9) of WBGST/CGST Act 2017 and remanded for fresh consideration. The adjudicating authority failed to address key submissions regarding input tax credit claims against supplies from deregistered vendors, particularly concerning retrospective cancellation of supplier registrations and proof of goods movement. The court found procedural deficiencies as the assessing officer did not record findings on precedents cited by assessee. Matter remanded for fresh adjudication with directions to consider all factual issues, legal principles, and grant personal hearing. Appellant permitted to submit fresh reply with supporting documentation and judicial precedents.
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