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 determined that the contractor was liable to pay GST at 18% on taxable turnover from works contract, while respondent had only reimbursed 12%. Based on contractual obligations requiring full GST reimbursement, which remained uncontested, respondent must pay the differential 6% GST amount. Court directed respondent to reimburse contractor for the difference between GST paid (18%) and amount already reimbursed (12%). Additionally, any interest charges levied by GST authorities for late payment must also be reimbursed by respondent. Writ petition disposed with directions for differential GST reimbursement.
HC determined that the contractor was liable to pay GST at 18% on taxable turnover from works contract, while respondent had only reimbursed 12%. Based on contractual obligations requiring full GST reimbursement, which remained uncontested, respondent must pay the differential 6% GST amount. Court directed respondent to reimburse contractor for the difference between GST paid (18%) and amount already reimbursed (12%). Additionally, any interest charges levied by GST authorities for late payment must also be reimbursed by respondent. Writ petition disposed with directions for differential GST reimbursement.
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