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...
IGST refund on exports cannot be confined to a request to amend shipping bills under Section 149 when an independent refund prayer under Rule 96 is on record. The refund rejection was set aside because the authority considered only the alleged lack of contemporaneous evidence for amendment and failed to examine the refund claim on its own merits. As export of goods and payment of IGST were undisputed, and none of the Rule 96(4) withholding contingencies applied, the refund had to be processed under the statutory refund mechanism; the amendment issue was left open.
IGST refund on exports cannot be confined to a request to amend shipping bills under Section 149 when an independent refund prayer under Rule 96 is on record. The refund rejection was set aside because the authority considered only the alleged lack of contemporaneous evidence for amendment and failed to examine the refund claim on its own merits. As export of goods and payment of IGST were undisputed, and none of the Rule 96(4) withholding contingencies applied, the refund had to be processed under the statutory refund mechanism; the amendment issue was left open.
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