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...
TDS refunds quantified under an assessment or appellate order under Section 201 constitute a crystallised entitlement carrying statutory interest. Form 26B, which concerns processing and adjustment of TDS statements under Section 200A and Rule 31A, cannot be required for such post-assessment refunds. Outstanding demands may justify withholding or adjustment only through a legally valid order under Section 245; demands linked to the assessee's PAN or sister TANs do not otherwise permit withholding. The quantified refunds were directed to be released with applicable interest, with additional interest for default.
TDS refunds quantified under an assessment or appellate order under Section 201 constitute a crystallised entitlement carrying statutory interest. Form 26B, which concerns processing and adjustment of TDS statements under Section 200A and Rule 31A, cannot be required for such post-assessment refunds. Outstanding demands may justify withholding or adjustment only through a legally valid order under Section 245; demands linked to the assessee's PAN or sister TANs do not otherwise permit withholding. The quantified refunds were directed to be released with applicable interest, with additional interest for default.
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