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...
Section 132B(4) requires simple interest on refundable seized cash from the day after expiry of 120 days from the last authorisation, and the Revenue cannot defeat that liability by relying on its own failure to complete assessment. Where refund is unduly delayed and no assessment has been made, Article 226 may support compensatory relief beyond the statutory framework. A pending vigilance reference does not justify withholding or postponing interest. The respondents were directed to pay interest on the refunded cash at the statutory rate until refund, with enhanced interest if payment was further delayed.
Section 132B(4) requires simple interest on refundable seized cash from the day after expiry of 120 days from the last authorisation, and the Revenue cannot defeat that liability by relying on its own failure to complete assessment. Where refund is unduly delayed and no assessment has been made, Article 226 may support compensatory relief beyond the statutory framework. A pending vigilance reference does not justify withholding or postponing interest. The respondents were directed to pay interest on the refunded cash at the statutory rate until refund, with enhanced interest if payment was further delayed.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4800
Join Channel
TaxTMI 
