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 quashed the impugned order insofar as it adjudicated the petitioners' claim for input tax credit as time-barred under Section 16(4) of the CGST Act, 2017, while recognizing entitlement where claims fall within the temporal window prescribed by Section 16(5). The respondent department is restrained from initiating or pursuing any proceedings against the petitioner premised solely on the limitation issue addressed by the order. The court directed the respondent to take immediate steps to de-freeze the petitioners' bank accounts affected by the impugned order. The writ petition is allowed, with the relief confined to the limitation question and ancillary de-freezing relief.
HC quashed the impugned order insofar as it adjudicated the petitioners' claim for input tax credit as time-barred under Section 16(4) of the CGST Act, 2017, while recognizing entitlement where claims fall within the temporal window prescribed by Section 16(5). The respondent department is restrained from initiating or pursuing any proceedings against the petitioner premised solely on the limitation issue addressed by the order. The court directed the respondent to take immediate steps to de-freeze the petitioners' bank accounts affected by the impugned order. The writ petition is allowed, with the relief confined to the limitation question and ancillary de-freezing relief.
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