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 held that a registered dealer cannot claim Input Tax Credit (ITC) for goods remaining in closing stock that were not re-sold before GST regime introduction. The court determined that since the goods were unsold at the transition point (1.7.2017), the dealer cannot treat the input tax as credit. The judgment affirmed that GST Act's implementation effectively terminated ITC entitlements under the previous VAT Act for unsold inventory. By referencing precedent in S/S Janki Industries, the court conclusively ruled against the dealer's claim, allowing revision and denying ITC carry-forward for unsold stock.
HC held that a registered dealer cannot claim Input Tax Credit (ITC) for goods remaining in closing stock that were not re-sold before GST regime introduction. The court determined that since the goods were unsold at the transition point (1.7.2017), the dealer cannot treat the input tax as credit. The judgment affirmed that GST Act's implementation effectively terminated ITC entitlements under the previous VAT Act for unsold inventory. By referencing precedent in S/S Janki Industries, the court conclusively ruled against the dealer's claim, allowing revision and denying ITC carry-forward for unsold stock.
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