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 and quashed the impugned notice, impugned order and subsequent communication, holding that the petitioner's shortfall in tax for March-April 2020 had been discharged in the GSTR-3B filed and verified by the revenue authority. The court set aside the impugned proceedings and remanded the matter to the concerned authority for fresh consideration under the CGST/SGST regime, particularly with regard to liability assessment and consequences under Section 73, taking into account the factual matrix reflected in the record and the Assistant Commissioner's instructions. Relief was granted by way of remand for reassessment without directing substantive relief on interest or penalty.
The HC allowed the petition and quashed the impugned notice, impugned order and subsequent communication, holding that the petitioner's shortfall in tax for March-April 2020 had been discharged in the GSTR-3B filed and verified by the revenue authority. The court set aside the impugned proceedings and remanded the matter to the concerned authority for fresh consideration under the CGST/SGST regime, particularly with regard to liability assessment and consequences under Section 73, taking into account the factual matrix reflected in the record and the Assistant Commissioner's instructions. Relief was granted by way of remand for reassessment without directing substantive relief on interest or penalty.
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