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...
Refund claim - Unjust enrichment - Chartered Accountant certificate indicates the bifurcation of the amounts towards maintenance charges and operation charges and has specifically certified assessee has not passed on the service tax liability on the operations part to any one and has borne the burden of the service tax - refund allowed - AT
Refund claim - Unjust enrichment - Chartered Accountant certificate indicates the bifurcation of the amounts towards maintenance charges and operation charges and has specifically certified assessee has not passed on the service tax liability on the operations part to any one and has borne the burden of the service tax - refund allowed - AT
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