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 unutilized CENVAT Credit - The period involved is April, 2017 to June, 2017 and the refund claim was made in June, 2018, which is perhaps within the period of one year but, however, by that time it is an undisputed fact that the GST regime had taken over by which filing of ST-3 Return was done-away. There is also no denial by the Revenue as to the claim of the appellant that subsequent to the filing of TRAN-1 Return, the refund amount was debited in its GSTR-3B/Electronic Credit Ledger - The denial of refund is not in accordance with law - AT
Refund of unutilized CENVAT Credit - The period involved is April, 2017 to June, 2017 and the refund claim was made in June, 2018, which is perhaps within the period of one year but, however, by that time it is an undisputed fact that the GST regime had taken over by which filing of ST-3 Return was done-away. There is also no denial by the Revenue as to the claim of the appellant that subsequent to the filing of TRAN-1 Return, the refund amount was debited in its GSTR-3B/Electronic Credit Ledger - The denial of refund is not in accordance with law - AT
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