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 quashed the impugned administrative action insofar as it rejected input tax credit asserted for FY 2018-19, holding that Section 16(5) prima facie extended the return-filing period until 30 November 2021 and thus rendered the reasoning for denial unsustainable. The court declined to pass a definitive substantive decree given the availability of statutory appellate remedy and the appealable character of the order; however, on the unique facts and prima facie satisfaction that the petitioner is entitled to the credit/refund, the HC waived the statutory pre-deposit requirement. The petition is accordingly disposed of, subject to the petitioner pursuing the appellate remedy.
The HC quashed the impugned administrative action insofar as it rejected input tax credit asserted for FY 2018-19, holding that Section 16(5) prima facie extended the return-filing period until 30 November 2021 and thus rendered the reasoning for denial unsustainable. The court declined to pass a definitive substantive decree given the availability of statutory appellate remedy and the appealable character of the order; however, on the unique facts and prima facie satisfaction that the petitioner is entitled to the credit/refund, the HC waived the statutory pre-deposit requirement. The petition is accordingly disposed of, subject to the petitioner pursuing the appellate remedy.
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