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 refund rejection order under GST RFD-06 concerning export transactions with IGST payment. Petitioner, a manufacturer-exporter, made zero-rated supplies under Section 16 of IGST Act, 2017, through invoices dated April 17 and June 3, 2023, with corresponding shipping bills. Refund was withheld under Rule 96(4) due to data mismatch between shipping bills and GSTR-1. Court found violation of natural justice principles as petitioner wasn't given adequate opportunity to respond to show cause notice. Emphasizing benefit of doubt doctrine, HC invalidated refund rejection order dated September 25, 2024, directing fresh consideration of refund claim after providing proper hearing opportunity.
HC set aside refund rejection order under GST RFD-06 concerning export transactions with IGST payment. Petitioner, a manufacturer-exporter, made zero-rated supplies under Section 16 of IGST Act, 2017, through invoices dated April 17 and June 3, 2023, with corresponding shipping bills. Refund was withheld under Rule 96(4) due to data mismatch between shipping bills and GSTR-1. Court found violation of natural justice principles as petitioner wasn't given adequate opportunity to respond to show cause notice. Emphasizing benefit of doubt doctrine, HC invalidated refund rejection order dated September 25, 2024, directing fresh consideration of refund claim after providing proper hearing opportunity.
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