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 allowed petitioner's challenge regarding CENVAT credit utilization, affirming that input tax credit electronic ledger represents a unified wallet with compartments for IGST, CGST, and SGST. The court referenced prior precedent emphasizing that tax credit eligibility should be assessed based on total wallet balance, not individual compartments. The 3rd respondent was directed to issue fresh orders within two months, consistent with the judicial interpretation, effectively resolving the inadvertent tax credit mismatch between GSTR 3B and GSTR 2A forms.
HC allowed petitioner's challenge regarding CENVAT credit utilization, affirming that input tax credit electronic ledger represents a unified wallet with compartments for IGST, CGST, and SGST. The court referenced prior precedent emphasizing that tax credit eligibility should be assessed based on total wallet balance, not individual compartments. The 3rd respondent was directed to issue fresh orders within two months, consistent with the judicial interpretation, effectively resolving the inadvertent tax credit mismatch between GSTR 3B and GSTR 2A forms.
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