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 blocking of the electronic credit ledger and denial of ITC, finding no violation of natural justice or jurisdictional error. Although the petitioner alleged non-availability of documents and lack of opportunity for cross-examination, the court observed that the petitioner's representative opposed re-examination and did not participate, and the adjudication order addressed the petitioner's responses comprehensively. The petitioner failed to utilize the appellate remedy and instead directly approached the HC. The court emphasized the petitioner's initial burden to produce evidence, including toll plaza reports, to substantiate transportation of goods, which was not discharged. Consequently, the State was not obligated to prove the petitioner's claim. The petitioner's reliance on a separate case concerning public auction and refund was deemed inapplicable. No illegality or irregularity was found in the proper officer's order, leading to dismissal of the petition.
The HC dismissed the petition challenging the blocking of the electronic credit ledger and denial of ITC, finding no violation of natural justice or jurisdictional error. Although the petitioner alleged non-availability of documents and lack of opportunity for cross-examination, the court observed that the petitioner's representative opposed re-examination and did not participate, and the adjudication order addressed the petitioner's responses comprehensively. The petitioner failed to utilize the appellate remedy and instead directly approached the HC. The court emphasized the petitioner's initial burden to produce evidence, including toll plaza reports, to substantiate transportation of goods, which was not discharged. Consequently, the State was not obligated to prove the petitioner's claim. The petitioner's reliance on a separate case concerning public auction and refund was deemed inapplicable. No illegality or irregularity was found in the proper officer's order, leading to dismissal of the petition.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4796
Join Channel
TaxTMI 
