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...
Statutory interest on a refunded investigation deposit treated as a pre-deposit is confined to the rate prescribed by the governing provision and notification. Where the statute creates the right to interest and fixes the rate, the claimant cannot seek a higher amount on equitable or restitutionary grounds unless the provision or notification itself is challenged. Applying that principle, the Court upheld interest at 6% per annum and rejected the claim for a higher rate, holding that no substantial question of law arose and dismissing the appeal.
Statutory interest on a refunded investigation deposit treated as a pre-deposit is confined to the rate prescribed by the governing provision and notification. Where the statute creates the right to interest and fixes the rate, the claimant cannot seek a higher amount on equitable or restitutionary grounds unless the provision or notification itself is challenged. Applying that principle, the Court upheld interest at 6% per annum and rejected the claim for a higher rate, holding that no substantial question of law arose and dismissing the appeal.
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