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...
Conversion of an adjudication order under the penalty provision to the regular adjudication provision was contested on whether requisite documentary evidence supported claimed input tax credit (ITC). The court found the adjudicating authority had recorded absence of tax invoices and returns and specific findings of deliberate availing of ineligible ITC amounting to fraud, misstatement or suppression; a prior, different-year case was distinguishable because documents had been produced there. In consequence, conversion to the regular provision was refused for want of supporting records and the writ petition failed.
Conversion of an adjudication order under the penalty provision to the regular adjudication provision was contested on whether requisite documentary evidence supported claimed input tax credit (ITC). The court found the adjudicating authority had recorded absence of tax invoices and returns and specific findings of deliberate availing of ineligible ITC amounting to fraud, misstatement or suppression; a prior, different-year case was distinguishable because documents had been produced there. In consequence, conversion to the regular provision was refused for want of supporting records and the writ petition failed.
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