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 upheld the denial of input tax credit (ITC) claimed on invoices related to motor vehicle purchase, repair, and maintenance, finding violations of Sections 16(1), 16(2), and 17(5) of the CGST Act, 2017, and Section 20 of the IGST Act, 2017. The petitioner failed to demonstrate payment to sundry creditors within the mandatory 180-day period as required under Section 16(2), relying solely on a chart without furnishing corroborative bank statements or documentary evidence. The Court affirmed the proper officer's conclusion that the petitioner did not substantiate timely payment, thereby justifying disallowance of excess ITC availed in GSTR-3B vis-Ã -vis GSTR-2A. Jurisdictional validity of the authority's action was not disputed, and partial compliance with the order was acknowledged. The petition challenging the officer's evaluation of evidence was dismissed, and the matter was disposed of accordingly.
The HC upheld the denial of input tax credit (ITC) claimed on invoices related to motor vehicle purchase, repair, and maintenance, finding violations of Sections 16(1), 16(2), and 17(5) of the CGST Act, 2017, and Section 20 of the IGST Act, 2017. The petitioner failed to demonstrate payment to sundry creditors within the mandatory 180-day period as required under Section 16(2), relying solely on a chart without furnishing corroborative bank statements or documentary evidence. The Court affirmed the proper officer's conclusion that the petitioner did not substantiate timely payment, thereby justifying disallowance of excess ITC availed in GSTR-3B vis-Ã -vis GSTR-2A. Jurisdictional validity of the authority's action was not disputed, and partial compliance with the order was acknowledged. The petition challenging the officer's evaluation of evidence was dismissed, and the matter was disposed of accordingly.
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