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 petition challenging the rejection of a rectification application concerning a mismatch in Form GSTR 3B due to a supplier's failure to file Form GSTR-01. The petitioner failed to respond to the show cause notice, leading to the issuance of the assessment order. The rectification application was rejected as no error apparent on the face of the record existed in the original order. The court held that factual disputes raised by the petitioner must be addressed during the assessment process, not through rectification proceedings. Consequently, the impugned order was affirmed, and no interference was warranted. The petition was dismissed.
The HC dismissed the petition challenging the rejection of a rectification application concerning a mismatch in Form GSTR 3B due to a supplier's failure to file Form GSTR-01. The petitioner failed to respond to the show cause notice, leading to the issuance of the assessment order. The rectification application was rejected as no error apparent on the face of the record existed in the original order. The court held that factual disputes raised by the petitioner must be addressed during the assessment process, not through rectification proceedings. Consequently, the impugned order was affirmed, and no interference was warranted. The petition was dismissed.
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