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 dismissed the petition challenging GST demand for AY 2017-2020. Petitioner allegedly facilitated tax evasion by passing ineligible Input Tax Credit (ITC). While petitioner claimed discharge of tax liability through ITC from supplier invoices, court found prima facie evidence of petitioner acting as accessory in passing ineligible ITC. Following precedent set in Sahyadri Industries Limited case, HC held that despite tax liability being met through ITC without cash payment, the transaction indicated fraudulent ITC passing scheme under CGST Act 2017 and TNGST Act 2017, warranting dismissal of relief sought.
HC dismissed the petition challenging GST demand for AY 2017-2020. Petitioner allegedly facilitated tax evasion by passing ineligible Input Tax Credit (ITC). While petitioner claimed discharge of tax liability through ITC from supplier invoices, court found prima facie evidence of petitioner acting as accessory in passing ineligible ITC. Following precedent set in Sahyadri Industries Limited case, HC held that despite tax liability being met through ITC without cash payment, the transaction indicated fraudulent ITC passing scheme under CGST Act 2017 and TNGST Act 2017, warranting dismissal of relief sought.
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