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 the petitioner's challenge to the rejection of ITC claim, finding a procedural error in the original orders. The court determined that physical movement of goods is not the sole criterion for ITC eligibility. The matter was remanded to the Deputy Commissioner to re-examine the case, specifically focusing on verifying the memorandum of understanding between the dealer and supplier, and assessing the documentation related to goods delivery. The court directed a fresh review of the ITC claim under Section 16(2)(b) of CGST Act, emphasizing the need for comprehensive examination of transaction details and supporting evidence.
HC allowed the petitioner's challenge to the rejection of ITC claim, finding a procedural error in the original orders. The court determined that physical movement of goods is not the sole criterion for ITC eligibility. The matter was remanded to the Deputy Commissioner to re-examine the case, specifically focusing on verifying the memorandum of understanding between the dealer and supplier, and assessing the documentation related to goods delivery. The court directed a fresh review of the ITC claim under Section 16(2)(b) of CGST Act, emphasizing the need for comprehensive examination of transaction details and supporting evidence.
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