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 the writ petition challenging the impugned order regarding ineligible ITC availed and utilized. The court found that the proper officer had complied with principles of natural justice by granting a hearing and considering the petitioner's contentions. The petitioner admitted wrongful availment of ITC for April to December 2020, which was subsequently reversed. The authority noted the absence of evidence for receipt of goods or services and corresponding payment. The petitioner's claim that certain documents were not fully considered did not justify invoking extraordinary jurisdiction, especially given the availability of effective alternative statutory remedies. The petitioner was granted liberty to pursue such remedies in accordance with law.
The HC dismissed the writ petition challenging the impugned order regarding ineligible ITC availed and utilized. The court found that the proper officer had complied with principles of natural justice by granting a hearing and considering the petitioner's contentions. The petitioner admitted wrongful availment of ITC for April to December 2020, which was subsequently reversed. The authority noted the absence of evidence for receipt of goods or services and corresponding payment. The petitioner's claim that certain documents were not fully considered did not justify invoking extraordinary jurisdiction, especially given the availability of effective alternative statutory remedies. The petitioner was granted liberty to pursue such remedies in accordance with law.
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