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 held that the retrospective extension of the time limit to avail input tax credit under sub-section (4) of Section 16 of the CGST Act, as per the Ministry of Finance circular dated 15-10-2024, permits taxpayers to seek rectification of orders passed under Sections 73, 74, 107, or 108 of the CGST Act regarding wrongful input tax credit claims. Pursuant to the special procedure under Section 148, notified on 8-10-2024, rectification applications may be filed within six months from 15-10-2024, i.e., until 15-4-2025. The petitioner was granted leave to file such an application, and the petition was accordingly disposed of.
The HC held that the retrospective extension of the time limit to avail input tax credit under sub-section (4) of Section 16 of the CGST Act, as per the Ministry of Finance circular dated 15-10-2024, permits taxpayers to seek rectification of orders passed under Sections 73, 74, 107, or 108 of the CGST Act regarding wrongful input tax credit claims. Pursuant to the special procedure under Section 148, notified on 8-10-2024, rectification applications may be filed within six months from 15-10-2024, i.e., until 15-4-2025. The petitioner was granted leave to file such an application, and the petition was accordingly disposed of.
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