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 dismissed the petition at the motion stage, holding that under Section 79(1)(a) of the CGST Act the revenue was entitled to recover tax dues from amounts owing to the taxpayer; an assessment dated 25.02.2025 fixed a demand of Rs. 10,32,672, for which 30 days' payment was granted but unpaid, and Rs. 2,87,914 was lawfully debited from the petitioner's Electronic Credit Ledger on 19.06.2025. The petitioner's rectification application was rejected and the appeal instituted thereafter did not attract any stay; in the absence of any interlocutory relief the post-assessment recovery was held neither perverse nor illegal.
The HC dismissed the petition at the motion stage, holding that under Section 79(1)(a) of the CGST Act the revenue was entitled to recover tax dues from amounts owing to the taxpayer; an assessment dated 25.02.2025 fixed a demand of Rs. 10,32,672, for which 30 days' payment was granted but unpaid, and Rs. 2,87,914 was lawfully debited from the petitioner's Electronic Credit Ledger on 19.06.2025. The petitioner's rectification application was rejected and the appeal instituted thereafter did not attract any stay; in the absence of any interlocutory relief the post-assessment recovery was held neither perverse nor illegal.
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