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 affirmed that blocking under Rule 86A of Orissa GST Rules serves as revenue security by preventing utilization of future ITC through negative balance insertion in electronic credit ledger. The court emphasized the necessity for tax authorities to initiate recovery proceedings within the one-year blocking period, as automatic unblocking would otherwise allow dealers to access and debit ITC from their electronic ledger. The temporary restriction mechanism ensures tax authorities can secure potential recoveries while maintaining procedural safeguards. The ruling clarifies that such preventive measures are valid when aligned with proper recovery actions within the prescribed timeframe.
HC affirmed that blocking under Rule 86A of Orissa GST Rules serves as revenue security by preventing utilization of future ITC through negative balance insertion in electronic credit ledger. The court emphasized the necessity for tax authorities to initiate recovery proceedings within the one-year blocking period, as automatic unblocking would otherwise allow dealers to access and debit ITC from their electronic ledger. The temporary restriction mechanism ensures tax authorities can secure potential recoveries while maintaining procedural safeguards. The ruling clarifies that such preventive measures are valid when aligned with proper recovery actions within the prescribed timeframe.
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