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...
Retrospective amendment of the Foreign Trade Policy cannot deprive exporters or service providers of SEIS benefits accrued while an operative scheme covered their eligible services. The power to formulate or amend the policy does not authorise retrospective withdrawal of such accrued rights. Services rendered and foreign exchange earned during FY 2019-20 remained eligible despite later notifications introducing Appendix 3X and excluding specified services under Appendix 3E. The notifications operate prospectively from their respective issue dates, requiring processing of accrued SEIS claims and consequential benefits, including claims that could not previously be filed.
Retrospective amendment of the Foreign Trade Policy cannot deprive exporters or service providers of SEIS benefits accrued while an operative scheme covered their eligible services. The power to formulate or amend the policy does not authorise retrospective withdrawal of such accrued rights. Services rendered and foreign exchange earned during FY 2019-20 remained eligible despite later notifications introducing Appendix 3X and excluding specified services under Appendix 3E. The notifications operate prospectively from their respective issue dates, requiring processing of accrued SEIS claims and consequential benefits, including claims that could not previously be filed.
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