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...
Entitlement to input tax credit was reconsidered in light of subsequent statutory insertions of Sections 16(5) and 16(6); because the impugned order denied credit solely on the ground of belated availment under Section 16(4), the HC remitted the matter for fresh adjudication so the respondent must re-examine entitlement on merits leaving aside the belated-availment ground and decide after hearing the petitioner. The court granted conditional interim relief by directing the petitioner to pay amounts due for belated returns and file a reply within 30 days; on compliance and absence of other arrears the bank attachment will be lifted pending final adjudication.
Entitlement to input tax credit was reconsidered in light of subsequent statutory insertions of Sections 16(5) and 16(6); because the impugned order denied credit solely on the ground of belated availment under Section 16(4), the HC remitted the matter for fresh adjudication so the respondent must re-examine entitlement on merits leaving aside the belated-availment ground and decide after hearing the petitioner. The court granted conditional interim relief by directing the petitioner to pay amounts due for belated returns and file a reply within 30 days; on compliance and absence of other arrears the bank attachment will be lifted pending final adjudication.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4794
Join Channel
TaxTMI 
