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 allowed the writ petition challenging dismissal of rectification application concerning ITC entitlement under TNGST/CGST Act 2017. Court found petitioner established prima facie case for interference, noting amendments to Section 16 and potential limitation issues under Section 14 of Limitation Act 1963 favoring petitioner. HC observed respondent summarily rejected rectification application against assessment order without proper discussion or consideration of merits. Consequently, HC quashed the impugned order and directed respondent to pass fresh order after examining petitioner's submissions on merits. Petition disposed of with directions for reconsideration.
HC allowed the writ petition challenging dismissal of rectification application concerning ITC entitlement under TNGST/CGST Act 2017. Court found petitioner established prima facie case for interference, noting amendments to Section 16 and potential limitation issues under Section 14 of Limitation Act 1963 favoring petitioner. HC observed respondent summarily rejected rectification application against assessment order without proper discussion or consideration of merits. Consequently, HC quashed the impugned order and directed respondent to pass fresh order after examining petitioner's submissions on merits. Petition disposed of with directions for reconsideration.
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