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...
Extra Duty Deposit in related-party provisional assessment proceedings is refundable once final valuation shows no further duty payable, because the deposit is not customs duty and does not survive as a deficiency payment. On delayed refund, the Section 27A interest principle applies mutatis mutandis: interest runs from expiry of three months after the refund entitlement arises until actual payment, even if the amount had earlier been credited to the Consumer Welfare Fund on unjust enrichment grounds. The denial of interest was set aside and refund interest was held payable.
Extra Duty Deposit in related-party provisional assessment proceedings is refundable once final valuation shows no further duty payable, because the deposit is not customs duty and does not survive as a deficiency payment. On delayed refund, the Section 27A interest principle applies mutatis mutandis: interest runs from expiry of three months after the refund entitlement arises until actual payment, even if the amount had earlier been credited to the Consumer Welfare Fund on unjust enrichment grounds. The denial of interest was set aside and refund interest was held payable.
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