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 of service tax - time limitation - refund sought on the ground that, they have paid Service Tax and GST on the same four transactions - when the Service Tax was paid on the basis of self-assessment and declaration in their ST 3 Returns for the period April to June 2017, the Service Tax was paid correctly for the services which were provided during the period April to June 2017 as per Section 68 of the Act - No refund.
Refund of service tax - time limitation - refund sought on the ground that, they have paid Service Tax and GST on the same four transactions - when the Service Tax was paid on the basis of self-assessment and declaration in their ST 3 Returns for the period April to June 2017, the Service Tax was paid correctly for the services which were provided during the period April to June 2017 as per Section 68 of the Act - No refund.
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