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 petition regarding GST input tax credit rectification. The court found no procedural prejudice to the petitioner, who was fully aware of the case against it involving inter-mingling of IGST and Cess input tax credits for February and March 2018. Referencing SC precedent, the court held that when a fair hearing would not alter the ultimate conclusion, no legal duty to provide additional notice exists. The petitioner failed to demonstrate substantial prejudice from the procedural approach, and the audit report sufficiently outlined the case. Consequently, the petition was dismissed without merit.
HC dismissed petition regarding GST input tax credit rectification. The court found no procedural prejudice to the petitioner, who was fully aware of the case against it involving inter-mingling of IGST and Cess input tax credits for February and March 2018. Referencing SC precedent, the court held that when a fair hearing would not alter the ultimate conclusion, no legal duty to provide additional notice exists. The petitioner failed to demonstrate substantial prejudice from the procedural approach, and the audit report sufficiently outlined the case. Consequently, the petition was dismissed without merit.
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