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...
Where import duty was paid through duty credit scrips, any drawback under section 74 or refund under section 27 of the Customs Act, 1962 is to be granted by re-credit, not in cash. For RoDTEP/RoSCTL scrips, the amount is to be re-credited to the IEC holder's electronic credit ledger and may be used for generation of e-scrips under the prescribed scheme. For legacy scrips such as MEIS or SEIS, where direct re-credit is not feasible, Customs must issue a re-credit certificate containing the utilised scrip details, import date and debited amount. The circular also notes that CBIC will issue further system guidance after module development.
Where import duty was paid through duty credit scrips, any drawback under section 74 or refund under section 27 of the Customs Act, 1962 is to be granted by re-credit, not in cash. For RoDTEP/RoSCTL scrips, the amount is to be re-credited to the IEC holder's electronic credit ledger and may be used for generation of e-scrips under the prescribed scheme. For legacy scrips such as MEIS or SEIS, where direct re-credit is not feasible, Customs must issue a re-credit certificate containing the utilised scrip details, import date and debited amount. The circular also notes that CBIC will issue further system guidance after module development.
Note: It is a system-generated summary and is for quick reference only.
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