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 consolidation of a single SCN spanning multiple tax years concerning alleged fraudulent availing of Input Tax Credit exceeding Rs.89 crores, holding that consolidation is permissible where primary allegation is fraudulent ITC. The court observed the impugned order is appealable under Section 107 of the CGST Act, 2017, and accordingly disposed of the petition while granting the Petitioner liberty to file an appeal by 30 September 2025 subject to compliance with requisite pre-deposit conditions. The disposal is without prejudice to the appellate forum's adjudication on merits and any statutory or equitable defenses available to the parties.
The HC dismissed the petition challenging consolidation of a single SCN spanning multiple tax years concerning alleged fraudulent availing of Input Tax Credit exceeding Rs.89 crores, holding that consolidation is permissible where primary allegation is fraudulent ITC. The court observed the impugned order is appealable under Section 107 of the CGST Act, 2017, and accordingly disposed of the petition while granting the Petitioner liberty to file an appeal by 30 September 2025 subject to compliance with requisite pre-deposit conditions. The disposal is without prejudice to the appellate forum's adjudication on merits and any statutory or equitable defenses available to the parties.
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