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...
Omission of Rule 96(10) of the CGST Rules, without a saving or sunset clause, ends the export-refund restriction for pending proceedings concerning integrated tax paid on exported goods and services. Applying the principle that an omitted provision cannot be kept alive without express preservation, communications founded on the former restriction cannot sustain denial of such refunds.
Omission of Rule 96(10) of the CGST Rules, without a saving or sunset clause, ends the export-refund restriction for pending proceedings concerning integrated tax paid on exported goods and services. Applying the principle that an omitted provision cannot be kept alive without express preservation, communications founded on the former restriction cannot sustain denial of such refunds.
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