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 and upheld that consolidation of a single SCN for multiple years is permissible where Input Tax Credit in excess of Rs. 41 crores is alleged to have been fraudulently availed; the primary allegation against the Petitioner mirrors that precedent. The court recorded that the impugned order is appealable under Section 107 of the CGST Act, 2017, and granted the Petitioner liberty to file an appeal by 30 September 2025 upon making the requisite pre-deposits. If the appeal is instituted within the stipulated period, the Appellate Authority is directed not to reject it on limitation grounds but to decide the matter on its merits.
The HC dismissed the petition and upheld that consolidation of a single SCN for multiple years is permissible where Input Tax Credit in excess of Rs. 41 crores is alleged to have been fraudulently availed; the primary allegation against the Petitioner mirrors that precedent. The court recorded that the impugned order is appealable under Section 107 of the CGST Act, 2017, and granted the Petitioner liberty to file an appeal by 30 September 2025 upon making the requisite pre-deposits. If the appeal is instituted within the stipulated period, the Appellate Authority is directed not to reject it on limitation grounds but to decide the matter on its merits.
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