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 the writ petition challenging tax credit demand, finding systematic fraudulent ITC availing by the petitioner. The key supplier M/s Fortune Graphics Limited was untraceable, with its director admitting no actual goods supply occurred. While declining immediate judicial intervention, the HC permitted the petitioner to pursue appellate remedies under Section 107, mandating pre-deposit by 15th July, 2025. The court noted the need for detailed factual scrutiny regarding specific entity's ITC claims, which exceeded writ jurisdiction's scope. The petition was disposed of, allowing potential appellate challenge subject to prescribed legal procedures.
HC dismissed the writ petition challenging tax credit demand, finding systematic fraudulent ITC availing by the petitioner. The key supplier M/s Fortune Graphics Limited was untraceable, with its director admitting no actual goods supply occurred. While declining immediate judicial intervention, the HC permitted the petitioner to pursue appellate remedies under Section 107, mandating pre-deposit by 15th July, 2025. The court noted the need for detailed factual scrutiny regarding specific entity's ITC claims, which exceeded writ jurisdiction's scope. The petition was disposed of, allowing potential appellate challenge subject to prescribed legal procedures.
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