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 the assessment order under Section 74 of GST enactments. The court upheld the denial of Input Tax Credit due to the provisional nature of the credit and the supplier's failure to remit taxes to the government. The burden of proving the transaction's genuineness rests with the purchasing dealer. The court found no merit in the petitioner's arguments and conclusively rejected the challenge to the tax assessment, affirming the statutory provisions governing provisional credit and its reversal.
HC dismissed the writ petition challenging the assessment order under Section 74 of GST enactments. The court upheld the denial of Input Tax Credit due to the provisional nature of the credit and the supplier's failure to remit taxes to the government. The burden of proving the transaction's genuineness rests with the purchasing dealer. The court found no merit in the petitioner's arguments and conclusively rejected the challenge to the tax assessment, affirming the statutory provisions governing provisional credit and its reversal.
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