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...
The HC quashed the order blocking petitioner's Electronic Credit Ledger under Rule 86A of CGST/SGST Rules. The court found that the impugned order lacked independent reasoning, instead relying on enforcement authority reports which constituted "borrowed satisfaction." Additionally, no pre-decisional hearing was granted to the petitioner before blocking the ECL, violating principles of natural justice. The order merely stated the registered person was "found to be a bill trader and involved in issuance/availment in fake invoices" without providing substantive reasoning. The court determined these procedural and substantive defects rendered the blocking order legally untenable and allowed the petition.
The HC quashed the order blocking petitioner's Electronic Credit Ledger under Rule 86A of CGST/SGST Rules. The court found that the impugned order lacked independent reasoning, instead relying on enforcement authority reports which constituted "borrowed satisfaction." Additionally, no pre-decisional hearing was granted to the petitioner before blocking the ECL, violating principles of natural justice. The order merely stated the registered person was "found to be a bill trader and involved in issuance/availment in fake invoices" without providing substantive reasoning. The court determined these procedural and substantive defects rendered the blocking order legally untenable and allowed the petition.
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