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...
Electrical installations and their components for factory expansion do not qualify as 'plant and machinery' under the Explanation to Section 17(5) of the CGST Act because they are generic, serve multiple functions, and upon annexation become part of immovable property; consequence: input tax credit on GST paid for such electrical works is disallowed under the blocking provisions of Section 17(5). Because ITC is denied on the merits, issues concerning timing or basis to claim ITC for supplier invoices treating amounts as advances and subsequent adjustments were deemed inapplicable and were not considered further.
Electrical installations and their components for factory expansion do not qualify as 'plant and machinery' under the Explanation to Section 17(5) of the CGST Act because they are generic, serve multiple functions, and upon annexation become part of immovable property; consequence: input tax credit on GST paid for such electrical works is disallowed under the blocking provisions of Section 17(5). Because ITC is denied on the merits, issues concerning timing or basis to claim ITC for supplier invoices treating amounts as advances and subsequent adjustments were deemed inapplicable and were not considered further.
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