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 established precedents and CBIC Circular No.128/47/2019-GST mandating DIN, the court held that non-inclusion of DIN invalidates tax proceedings. While quashing the impugned order dated 17-10-2024, HC granted liberty to tax authorities to initiate fresh assessment after proper notice and DIN assignment. The ruling reinforces procedural compliance requirement of DIN in GST proceedings as a mandatory safeguard, consistent with prior Division Bench decisions in similar matters involving procedural irregularities in tax assessments.
HC set aside GST assessment proceedings due to absence of Document Identification Number (DIN). Following established precedents and CBIC Circular No.128/47/2019-GST mandating DIN, the court held that non-inclusion of DIN invalidates tax proceedings. While quashing the impugned order dated 17-10-2024, HC granted liberty to tax authorities to initiate fresh assessment after proper notice and DIN assignment. The ruling reinforces procedural compliance requirement of DIN in GST proceedings as a mandatory safeguard, consistent with prior Division Bench decisions in similar matters involving procedural irregularities in tax assessments.
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