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...
IGST refunds withheld due to DGARM alerts continue to be transmitted to GSTN under Rule 96 of the CGST Rules, and a new ICES function now allows Additional/Joint Commissioners to mark shipping bills for GST refund processing through the added "GST Refund to be processed by GSTN" option in the ADDL role. For cases covered under Rule 96(4)(a) and 4(b), the transmission role under sub-rules 5A and 5B is shifted to the Additional/Joint Commissioner level. Field formations must ensure approval for such transmission in accordance with existing legal provisions.
IGST refunds withheld due to DGARM alerts continue to be transmitted to GSTN under Rule 96 of the CGST Rules, and a new ICES function now allows Additional/Joint Commissioners to mark shipping bills for GST refund processing through the added "GST Refund to be processed by GSTN" option in the ADDL role. For cases covered under Rule 96(4)(a) and 4(b), the transmission role under sub-rules 5A and 5B is shifted to the Additional/Joint Commissioner level. Field formations must ensure approval for such transmission in accordance with existing legal provisions.
Note: It is a system-generated summary and is for quick reference only.