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...
The HC dismissed a writ petition challenging GST assessment orders under Section 73(9) CGST/BGST Act, 2017. The petitioner claimed clerical errors caused turnover suppression totaling Rs.4,41,27,934.50 across December 2018 and January 2019 returns, with mismatches between GSTR-3B and GSTR-1 filings. The assessing authority quantified liability for suppressed turnover, wrongful input tax credit utilization, and delayed tax payment. The appellate authority found insufficient evidence per clarificatory circular dated 27.02.2022 and Section 16(2). The HC held the assessment orders contained no natural justice violations or jurisdictional errors, noting available statutory remedy before the Tribunal. The Court declined to exercise extraordinary writ jurisdiction where adequate alternative remedies existed.
The HC dismissed a writ petition challenging GST assessment orders under Section 73(9) CGST/BGST Act, 2017. The petitioner claimed clerical errors caused turnover suppression totaling Rs.4,41,27,934.50 across December 2018 and January 2019 returns, with mismatches between GSTR-3B and GSTR-1 filings. The assessing authority quantified liability for suppressed turnover, wrongful input tax credit utilization, and delayed tax payment. The appellate authority found insufficient evidence per clarificatory circular dated 27.02.2022 and Section 16(2). The HC held the assessment orders contained no natural justice violations or jurisdictional errors, noting available statutory remedy before the Tribunal. The Court declined to exercise extraordinary writ jurisdiction where adequate alternative remedies existed.
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