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 adjudicated a GST dispute involving retrospective cancellation of suppliers' registrations and input tax credit reversal. The court found the respondents' invocation of Section 168A to extend order-passing timelines under Section 73(9) was procedurally valid. Despite petitioner's argument of no force majeure conditions and challenging the notifications, the court noted the petitioner had disclosed invoices, ledgers, and e-way bills demonstrating good faith transactions. The court partially acknowledged the petitioner's submissions, particularly regarding acceptance of explanations for two suppliers. The matter was adjourned until 28th April, 2025, with the impugned order remained stayed pending further judicial review.
HC adjudicated a GST dispute involving retrospective cancellation of suppliers' registrations and input tax credit reversal. The court found the respondents' invocation of Section 168A to extend order-passing timelines under Section 73(9) was procedurally valid. Despite petitioner's argument of no force majeure conditions and challenging the notifications, the court noted the petitioner had disclosed invoices, ledgers, and e-way bills demonstrating good faith transactions. The court partially acknowledged the petitioner's submissions, particularly regarding acceptance of explanations for two suppliers. The matter was adjourned until 28th April, 2025, with the impugned order remained stayed pending further judicial review.
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