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 quashed the original and appellate orders under the CGST regime because a material factual claim regarding reversal and reclassification of input tax credit before the show cause notice had not been properly considered. The petitioner had raised the point earlier, but it was rejected for want of documentary support; however, the respondent later confirmed the correctness of that submission before the Court. On that limited basis, the Court held that the foundation of the impugned orders required reconsideration and remanded the matter to the adjudicatory authority for fresh decision expeditiously, leaving all merits open.
The HC quashed the original and appellate orders under the CGST regime because a material factual claim regarding reversal and reclassification of input tax credit before the show cause notice had not been properly considered. The petitioner had raised the point earlier, but it was rejected for want of documentary support; however, the respondent later confirmed the correctness of that submission before the Court. On that limited basis, the Court held that the foundation of the impugned orders required reconsideration and remanded the matter to the adjudicatory authority for fresh decision expeditiously, leaving all merits open.
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