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 directed the Respondent Department to re-credit the Petitioner's Input Tax Credit (ITC) of Rs. 23,32,278/- to the Petitioner's Electronic Credit Ledger within four weeks, permitting manual intervention if necessary, upon finding no dispute as to entitlement and that non-credit arose solely from a technical limitation of the GST portal preventing issuance of PMT-03. The court held that the refund cannot be withheld on account of the technical impediment and ordered immediate compliance with the re-crediting directive. The petition is disposed of accordingly.
The HC directed the Respondent Department to re-credit the Petitioner's Input Tax Credit (ITC) of Rs. 23,32,278/- to the Petitioner's Electronic Credit Ledger within four weeks, permitting manual intervention if necessary, upon finding no dispute as to entitlement and that non-credit arose solely from a technical limitation of the GST portal preventing issuance of PMT-03. The court held that the refund cannot be withheld on account of the technical impediment and ordered immediate compliance with the re-crediting directive. The petition is disposed of accordingly.
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