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 allowed the writ petition in part and disposed it with a mandatory direction: the respondents are ordered to enable facilities within one month to permit the petitioner to re-submit the TRAN-1 application with corrected entries and to furnish an opportunity to cure defects so the petitioner may claim transitional input tax credit for the pre-GST period. The court found the initial rejection resulted from the petitioner's erroneous data entry but held that mere procedural or software limitations do not warrant denial of substantive statutory relief; accordingly the petitioner retains the right to avail benefits under the transitional provisions upon compliance with the rectified submission.
The HC allowed the writ petition in part and disposed it with a mandatory direction: the respondents are ordered to enable facilities within one month to permit the petitioner to re-submit the TRAN-1 application with corrected entries and to furnish an opportunity to cure defects so the petitioner may claim transitional input tax credit for the pre-GST period. The court found the initial rejection resulted from the petitioner's erroneous data entry but held that mere procedural or software limitations do not warrant denial of substantive statutory relief; accordingly the petitioner retains the right to avail benefits under the transitional provisions upon compliance with the rectified submission.
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