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 ruled in favor of the petitioner regarding input tax credit (ITC) dispute under GST law. The court established that electronic credit ledger functions as a pool of funds with separate compartments for IGST, CGST, and SGST. Although petitioner utilized CGST and SGST credits instead of IGST, this did not constitute wrongful availment under Section 16(2)(c) of GST Act. Court set aside proceedings initiated under Section 73 of CGST Act, directing reconsideration of original orders. The ruling affirms that mere utilization of different tax head credits does not amount to improper ITC claim when overall credit pool is legitimate. Matter remanded for fresh consideration by tax authorities.
HC ruled in favor of the petitioner regarding input tax credit (ITC) dispute under GST law. The court established that electronic credit ledger functions as a pool of funds with separate compartments for IGST, CGST, and SGST. Although petitioner utilized CGST and SGST credits instead of IGST, this did not constitute wrongful availment under Section 16(2)(c) of GST Act. Court set aside proceedings initiated under Section 73 of CGST Act, directing reconsideration of original orders. The ruling affirms that mere utilization of different tax head credits does not amount to improper ITC claim when overall credit pool is legitimate. Matter remanded for fresh consideration by tax authorities.
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