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...
Claim of refund of export duty paid where goods could not be exported - Period of limitation - even though on payment of export duty, the Let Export Order (LEO) was received on 09.12.2011 - shipping bill was allowed to be cancelled only on 23.01.2013 and they had filed the refund claim on 10.05.2013. - Refund is beyond the normal period of limitation - AT
Claim of refund of export duty paid where goods could not be exported - Period of limitation - even though on payment of export duty, the Let Export Order (LEO) was received on 09.12.2011 - shipping bill was allowed to be cancelled only on 23.01.2013 and they had filed the refund claim on 10.05.2013. - Refund is beyond the normal period of limitation - AT
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