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 ruled that pursuant to clause (5) of Section 16 inserted by Finance (No.2) Act, 2024 and the circular dated 15.10.2024, the respondents' orders are set aside. The court directed respondents to permit petitioner's input tax credits for delayed returns filed during June 2018 to March 2019, effectively allowing retrospective tax credit claims despite initial administrative rejection. The judicial intervention ensures compliance with recent statutory amendments and provides relief to the taxpayer by mandating administrative reconsideration of previously denied input tax credit claims.
HC ruled that pursuant to clause (5) of Section 16 inserted by Finance (No.2) Act, 2024 and the circular dated 15.10.2024, the respondents' orders are set aside. The court directed respondents to permit petitioner's input tax credits for delayed returns filed during June 2018 to March 2019, effectively allowing retrospective tax credit claims despite initial administrative rejection. The judicial intervention ensures compliance with recent statutory amendments and provides relief to the taxpayer by mandating administrative reconsideration of previously denied input tax credit claims.
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