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...
Trade Notice amends the EPM-Niryat Disha guidelines by replacing the certification list with Annexure-I, expanding the eligible testing, inspection and certification entries. Financial assistance is now differentiated by MSME class: micro and small enterprises may receive up to 95% of actual cost, while medium enterprises may receive up to 80%, subject to the notified ceiling; the maximum cumulative reimbursement rises to 50 lakh per IEC, with higher support subject to Sub-Committee review. Support is now disbursed in two instalments, and reimbursement claims are split into RC-1 and RC-2, with export evidence required before the second claim. Failure to act within the prescribed timelines causes lapse and possible recovery.
Trade Notice amends the EPM-Niryat Disha guidelines by replacing the certification list with Annexure-I, expanding the eligible testing, inspection and certification entries. Financial assistance is now differentiated by MSME class: micro and small enterprises may receive up to 95% of actual cost, while medium enterprises may receive up to 80%, subject to the notified ceiling; the maximum cumulative reimbursement rises to 50 lakh per IEC, with higher support subject to Sub-Committee review. Support is now disbursed in two instalments, and reimbursement claims are split into RC-1 and RC-2, with export evidence required before the second claim. Failure to act within the prescribed timelines causes lapse and possible recovery.
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