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 petition challenging the demand and penalties totaling Rs. 8.83 crores for fraudulent ITC claims involving multiple non-existent firms and numerous noticees for FY 2017-18. The Court held that the petitioner must pursue the statutory appellate remedy rather than seek relief via writ jurisdiction, given the complexity and multiplicity of transactions underlying the ITC claims. The non-consideration of the petitioner's reply does not preclude filing an appeal with supporting documents. The Court noted that consolidated show cause notices were impracticable due to distinct transaction networks. Consequently, the HC declined to adjudicate on the merits under writ jurisdiction and disposed of the petition accordingly.
The HC dismissed the writ petition challenging the demand and penalties totaling Rs. 8.83 crores for fraudulent ITC claims involving multiple non-existent firms and numerous noticees for FY 2017-18. The Court held that the petitioner must pursue the statutory appellate remedy rather than seek relief via writ jurisdiction, given the complexity and multiplicity of transactions underlying the ITC claims. The non-consideration of the petitioner's reply does not preclude filing an appeal with supporting documents. The Court noted that consolidated show cause notices were impracticable due to distinct transaction networks. Consequently, the HC declined to adjudicate on the merits under writ jurisdiction and disposed of the petition accordingly.
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