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 determined that the respondent authority misconstrued the GST notification's applicability. The court held that paragraph 3(iv) of the notification applies exclusively to pre-GST contracts and cannot be used to deny reimbursement for contracts executed after July 1, 2017, which are governed by paragraph 4. The HC directed the public works department secretary to revisit the petitioner's claim regarding GST payment against gross bills from July 1, 2017 to March 31, 2019, in accordance with GST law, effectively remanding the matter for reconsideration and potential reimbursement.
HC determined that the respondent authority misconstrued the GST notification's applicability. The court held that paragraph 3(iv) of the notification applies exclusively to pre-GST contracts and cannot be used to deny reimbursement for contracts executed after July 1, 2017, which are governed by paragraph 4. The HC directed the public works department secretary to revisit the petitioner's claim regarding GST payment against gross bills from July 1, 2017 to March 31, 2019, in accordance with GST law, effectively remanding the matter for reconsideration and potential reimbursement.
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