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 examined proceedings under Section 73 of UP GST Act regarding disputed input tax credit claims. The authority initially rejected certificates filed per Government Order dated 27.12.2022, claiming absence of GSTN details. Upon review, HC found GSTN numbers were clearly mentioned in submitted certificates. Given this material discrepancy in assessment, HC remanded the matter to original authority for fresh consideration. Authority directed to review all materials, conduct stakeholder hearings, and issue reasoned order within three months of certified order copy production. Petition allowed through remand, emphasizing need for comprehensive review of documentation and proper procedural compliance in input tax credit determination.
HC examined proceedings under Section 73 of UP GST Act regarding disputed input tax credit claims. The authority initially rejected certificates filed per Government Order dated 27.12.2022, claiming absence of GSTN details. Upon review, HC found GSTN numbers were clearly mentioned in submitted certificates. Given this material discrepancy in assessment, HC remanded the matter to original authority for fresh consideration. Authority directed to review all materials, conduct stakeholder hearings, and issue reasoned order within three months of certified order copy production. Petition allowed through remand, emphasizing need for comprehensive review of documentation and proper procedural compliance in input tax credit determination.
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