Intra-group management-fee transfer pricing adjustments cannot...

Intra-group management-fee transfer pricing adjustments cannot be sustained where the issue has consistently been resolved in the taxpayer's favour on materially similar facts in earlier years. Tax refunds from customs and VAT/GST are balance-sheet items rather than income; any return-processing adjustment treating them as income requires factual verification and consequential relief under law. Claimed short credit for tax deducted at source must be verified after giving the taxpayer an opportunity to substantiate the claim. Interest charged under the applicable provisions requires recomputation and a clear section-wise bifurcation to enable verification of its correctness. The management-fee adjustment was deleted, while the remaining matters required verification or recomputation.