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...
Anti-profiteering proceedings may extend beyond the original complaint where the DGAP report warrants reconsideration, and Rule 133(4) supports further inquiry into wider products; the objection to jurisdiction was rejected. Omission of the rules constituting the former authority did not extinguish pending proceedings or prior orders, since the statutory anti-profiteering scheme continued through successor forums. The prescribed decision timeline was held directory, so delay did not bar the matter. The supplier was found to have failed to pass on a GST rate reduction by commensurate price reduction, and benefit had to reach each recipient. Interest and penalty were not imposed for the pre-amendment period because those provisions were introduced later.
Anti-profiteering proceedings may extend beyond the original complaint where the DGAP report warrants reconsideration, and Rule 133(4) supports further inquiry into wider products; the objection to jurisdiction was rejected. Omission of the rules constituting the former authority did not extinguish pending proceedings or prior orders, since the statutory anti-profiteering scheme continued through successor forums. The prescribed decision timeline was held directory, so delay did not bar the matter. The supplier was found to have failed to pass on a GST rate reduction by commensurate price reduction, and benefit had to reach each recipient. Interest and penalty were not imposed for the pre-amendment period because those provisions were introduced later.
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