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 appeal challenging Section 16(2)(c) of the CGST/SGST Act, which requires an assessee claiming input tax credit to ensure the supplier has paid the output tax. However, the court extended the time granted by the Single Judge by one month for the appellant to claim benefits under two specified circulars and to raise additional issues related to errors in Form GSTR-3B before the adjudicating authority. If the appellant approaches the assessing authority within this extended period highlighting the irregularities, the authority must consider the application under the liberty granted and adjudicate expeditiously. The remainder of the Single Judge's findings were upheld, and the writ appeal was disposed of accordingly.
The HC dismissed the writ appeal challenging Section 16(2)(c) of the CGST/SGST Act, which requires an assessee claiming input tax credit to ensure the supplier has paid the output tax. However, the court extended the time granted by the Single Judge by one month for the appellant to claim benefits under two specified circulars and to raise additional issues related to errors in Form GSTR-3B before the adjudicating authority. If the appellant approaches the assessing authority within this extended period highlighting the irregularities, the authority must consider the application under the liberty granted and adjudicate expeditiously. The remainder of the Single Judge's findings were upheld, and the writ appeal was disposed of accordingly.
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