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 petition in part and directed the petitioner to deposit 25% of the disputed tax within four weeks from the date of uploading of the web copy of the order; the court quashed the impugned Order-in-Original concerning short payment of IGST, discrepancies between GSTR-3B and GSTR-1 for April 2020-March 2021, alleged excess availment/utilization of ITC not reflected in GSTR-2A, reverse charge vs. GSTR-3B issues, ineligible ITC attributable to suppliers' non-filing, reversals under Rules 42/43, interest under Section 50, blocked credits under Section 17(5), and late fee under Section 47. The OIO No.31/2025-GST(Supdt.)(R-I) dated 25.02.2025 issued by the 1st respondent is quashed and the petition is disposed of.
The HC allowed the petition in part and directed the petitioner to deposit 25% of the disputed tax within four weeks from the date of uploading of the web copy of the order; the court quashed the impugned Order-in-Original concerning short payment of IGST, discrepancies between GSTR-3B and GSTR-1 for April 2020-March 2021, alleged excess availment/utilization of ITC not reflected in GSTR-2A, reverse charge vs. GSTR-3B issues, ineligible ITC attributable to suppliers' non-filing, reversals under Rules 42/43, interest under Section 50, blocked credits under Section 17(5), and late fee under Section 47. The OIO No.31/2025-GST(Supdt.)(R-I) dated 25.02.2025 issued by the 1st respondent is quashed and the petition is disposed of.
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