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...
Refund claim arising from EPCG-linked procurement was rejected because the supplier had shown the supply under general turnover instead of deemed exports, without giving the claimant an opportunity to produce supporting material. The Court treated the problem as a curable classification error and directed that the claim be reconsidered on merits if proper documents were furnished, including a Chartered Accountant's certificate. The rejection order was set aside and the matter remitted for fresh consideration upon submission of the required representation and evidence.
Refund claim arising from EPCG-linked procurement was rejected because the supplier had shown the supply under general turnover instead of deemed exports, without giving the claimant an opportunity to produce supporting material. The Court treated the problem as a curable classification error and directed that the claim be reconsidered on merits if proper documents were furnished, including a Chartered Accountant's certificate. The rejection order was set aside and the matter remitted for fresh consideration upon submission of the required representation and evidence.
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