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...
HC dismissed the writ petition and upheld the impugned order, holding the petitioner liable for late fees under Section 47(2) of the TN GST Act for failure to furnish the annual return (GSTR-9) for AY 2021-22 in violation of Section 44 read with Rule 80. The court found no merit in the challenge, noting the petitioner did not file the return within three years; issuance of a notice under Rule 68/GSTR-3A did not obviate liability. The petitioner remains liable to pay late fee calculated at Rs.100 per day subject to the statutory ceiling of one quarter percent of turnover, and the petition is dismissed.
HC dismissed the writ petition and upheld the impugned order, holding the petitioner liable for late fees under Section 47(2) of the TN GST Act for failure to furnish the annual return (GSTR-9) for AY 2021-22 in violation of Section 44 read with Rule 80. The court found no merit in the challenge, noting the petitioner did not file the return within three years; issuance of a notice under Rule 68/GSTR-3A did not obviate liability. The petitioner remains liable to pay late fee calculated at Rs.100 per day subject to the statutory ceiling of one quarter percent of turnover, and the petition is dismissed.
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