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 quashed the impugned order dated 30.12.2023 regarding interest levy for delayed GSTR 3B return filing. The court held that interest liability ceases upon tax deposit in the electronic cash ledger, relying on precedent in a similar case. Rule 88 B(1) of C.G. & S.T. Rules, 2017 was deemed clarificatory in nature, rendering retrospective/prospective effect arguments moot. The court left open the possibility of respondent taking action for other potential penalties or non-payments. The petition was disposed of, with interest levy specifically quashed while maintaining other potential enforcement mechanisms.
HC quashed the impugned order dated 30.12.2023 regarding interest levy for delayed GSTR 3B return filing. The court held that interest liability ceases upon tax deposit in the electronic cash ledger, relying on precedent in a similar case. Rule 88 B(1) of C.G. & S.T. Rules, 2017 was deemed clarificatory in nature, rendering retrospective/prospective effect arguments moot. The court left open the possibility of respondent taking action for other potential penalties or non-payments. The petition was disposed of, with interest levy specifically quashed while maintaining other potential enforcement mechanisms.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4796
Join Channel
TaxTMI 
