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 petitioners' challenge to the denial of input tax credit, finding that neither the assessment order nor subsequent authorities had adequately examined or verified the credit computation. The revisional authority's determination of allowable input tax credit at Rs. 36,36,100 under section 22(17) was upheld. The revisional Board's order was set aside, and the matter remanded to the AO to grant the specified credit and issue a revised assessment within eight weeks of receiving the judgment. The petition was allowed solely by way of remand to ensure the petitioners receive the input tax credit as determined by the revisional authority.
The HC dismissed the writ petitioners' challenge to the denial of input tax credit, finding that neither the assessment order nor subsequent authorities had adequately examined or verified the credit computation. The revisional authority's determination of allowable input tax credit at Rs. 36,36,100 under section 22(17) was upheld. The revisional Board's order was set aside, and the matter remanded to the AO to grant the specified credit and issue a revised assessment within eight weeks of receiving the judgment. The petition was allowed solely by way of remand to ensure the petitioners receive the input tax credit as determined by the revisional authority.
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