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, exercising extraordinary writ jurisdiction, set aside the impugned order refusing rectification under s.161 of the GST Act and ordered correction of a clerical/arithmetic error in the electronically filed figures whereby "Rs. 1,07,916.48" was erroneously recorded as "Rs. 1,07,91,648.00." The matter is remitted to the Assistant Commissioner (State Tax), CT & GST Circle, for consideration of the petition for rectification and for modification of the assessment order under s.73 accordingly. The authority is directed to permit the petitioner to rectify the mistake and give consequential effect to the correction within four weeks of receipt of this order. Petition disposed.
The HC, exercising extraordinary writ jurisdiction, set aside the impugned order refusing rectification under s.161 of the GST Act and ordered correction of a clerical/arithmetic error in the electronically filed figures whereby "Rs. 1,07,916.48" was erroneously recorded as "Rs. 1,07,91,648.00." The matter is remitted to the Assistant Commissioner (State Tax), CT & GST Circle, for consideration of the petition for rectification and for modification of the assessment order under s.73 accordingly. The authority is directed to permit the petitioner to rectify the mistake and give consequential effect to the correction within four weeks of receipt of this order. Petition disposed.
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