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...
Interest on delayed customs refunds of excess duty following reassessment commences after three months from receipt of the refund application, rather than from the later reassessment or refund order. Where the importer pursued reassessment and refund but Revenue delayed action for several years, the delay is attributable to Revenue. Interest was therefore payable from 20.02.2019 until the refund date. The applicable rate was 12 per cent, not 6 per cent, because the refund was withheld through prolonged inaction. The balance interest was required to be paid within eight weeks.
Interest on delayed customs refunds of excess duty following reassessment commences after three months from receipt of the refund application, rather than from the later reassessment or refund order. Where the importer pursued reassessment and refund but Revenue delayed action for several years, the delay is attributable to Revenue. Interest was therefore payable from 20.02.2019 until the refund date. The applicable rate was 12 per cent, not 6 per cent, because the refund was withheld through prolonged inaction. The balance interest was required to be paid within eight weeks.
Note: It is a system-generated summary and is for quick reference only.
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