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...
Withholding an electronic cash ledger refund during the Revenue's pending appeal requires a specific determination by the Commissioner under Section 54(11) of the CGST Act. Payment or withholding cannot be decided without initiating the statutory process, issuing a show cause notice, and providing the claimant a proper opportunity of hearing. The Commissioner must then pass a reasoned order determining whether the claimed refund should be paid or withheld while the appeal remains pending.
Withholding an electronic cash ledger refund during the Revenue's pending appeal requires a specific determination by the Commissioner under Section 54(11) of the CGST Act. Payment or withholding cannot be decided without initiating the statutory process, issuing a show cause notice, and providing the claimant a proper opportunity of hearing. The Commissioner must then pass a reasoned order determining whether the claimed refund should be paid or withheld while the appeal remains pending.
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