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 AT dismissed the DGAP's profiteering report and closed proceedings against the Respondent under Section 171, CGST Act, holding there is no admissible material establishing that the Respondent retained an unlawful benefit of input tax credit by failing to reduce prices. The AT noted mixed SKU price movements and absence of document evidence demonstrating overall profiteering; enquiries of 56 recipients showed 50 received ITC-related benefit, one was unregistered, and five were unreachable due to closure/liquidation/death. Consequently the DGAP's concluded profiteering amount was not accepted, no liability was fastened on the Respondent, and the complaint was thereby disposed.
The AT dismissed the DGAP's profiteering report and closed proceedings against the Respondent under Section 171, CGST Act, holding there is no admissible material establishing that the Respondent retained an unlawful benefit of input tax credit by failing to reduce prices. The AT noted mixed SKU price movements and absence of document evidence demonstrating overall profiteering; enquiries of 56 recipients showed 50 received ITC-related benefit, one was unregistered, and five were unreachable due to closure/liquidation/death. Consequently the DGAP's concluded profiteering amount was not accepted, no liability was fastened on the Respondent, and the complaint was thereby disposed.
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