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...
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Export valuation requires contemporaneous evidence; unrelated invoices cannot prove overvaluation, and dual penalties on firm and partner are impermis...
The HC held that the mis-typed GSTIN in self-assessed returns constituted an error apparent on the face of the record amenable to rectification as a bona fide clerical/arithmetic mistake; because the erroneous deposit was received by the same recipient entity and there was no allegation of double recovery or unjust enrichment, denial of rectification would amount to double taxation. The court directed the GST authorities to permit the petitioner to amend/rectify the returns for the 2023-24 tax periods and to dispose of the petitioner's representation within eight weeks from notice, and accordingly dismissed the petition as disposed following compliance.
The HC held that the mis-typed GSTIN in self-assessed returns constituted an error apparent on the face of the record amenable to rectification as a bona fide clerical/arithmetic mistake; because the erroneous deposit was received by the same recipient entity and there was no allegation of double recovery or unjust enrichment, denial of rectification would amount to double taxation. The court directed the GST authorities to permit the petitioner to amend/rectify the returns for the 2023-24 tax periods and to dispose of the petitioner's representation within eight weeks from notice, and accordingly dismissed the petition as disposed following compliance.
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