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 GST assessment proceedings due to absence of Document Identification Number (DIN). Following SC precedent in Pradeep Goyal case and CBIC circular No. 128/47/2019-GST, the court determined that orders without DIN are non-est and invalid. The ruling aligns with previous HC Division Bench decisions in Cluster Enterprises and Sai Manikanta cases which established that non-mention of DIN invalidates proceedings. Court granted liberty to revenue authorities to conduct fresh assessment after proper notice to assessee and assignment of DIN number. The Form GST DRC-07 dated 26.06.2024 was consequently invalidated, emphasizing procedural compliance requirement in GST administration.
HC set aside GST assessment proceedings due to absence of Document Identification Number (DIN). Following SC precedent in Pradeep Goyal case and CBIC circular No. 128/47/2019-GST, the court determined that orders without DIN are non-est and invalid. The ruling aligns with previous HC Division Bench decisions in Cluster Enterprises and Sai Manikanta cases which established that non-mention of DIN invalidates proceedings. Court granted liberty to revenue authorities to conduct fresh assessment after proper notice to assessee and assignment of DIN number. The Form GST DRC-07 dated 26.06.2024 was consequently invalidated, emphasizing procedural compliance requirement in GST administration.
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