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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 determined that holographic stickers supplied by the Prohibition and Excise Department constitute "goods" under Section 2(52) of GST laws, not services. The supply cannot be classified as a "composite supply" with excise licensing. The petitioner's previous RCM tax payments were made erroneously, as the stickers are not taxable supplies under Section 2(108). The court rejected the respondents' estoppel argument, affirming that tax principles are not bound by past practices. The second respondent must process refund claims under Section 54 of GST Acts and Rule 89 of GST rules within 3 months. The petition was allowed, granting refund of GST paid under reverse charge mechanism for holographic sticker procurement.
HC determined that holographic stickers supplied by the Prohibition and Excise Department constitute "goods" under Section 2(52) of GST laws, not services. The supply cannot be classified as a "composite supply" with excise licensing. The petitioner's previous RCM tax payments were made erroneously, as the stickers are not taxable supplies under Section 2(108). The court rejected the respondents' estoppel argument, affirming that tax principles are not bound by past practices. The second respondent must process refund claims under Section 54 of GST Acts and Rule 89 of GST rules within 3 months. The petition was allowed, granting refund of GST paid under reverse charge mechanism for holographic sticker procurement.
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