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 amount excessively debited from the Electronic Credit Ledger Account - Pre-deposit before filing of appeal - Since it is not in dispute that the petitioner has complied with the provisions laid down in Section 107(6)(b) of the CGST Act, it necessarily follows that the recovery proceedings for the balance amount shall be deemed to be stayed - the interest of the revenue has been well protected in the manner as specifically provided in the statute. This Court is thus of the considered view that the concerned respondent authority should be directed to restore back the amount which was debited from the electronic credit ledger account of the petitioner - HC
Refund of amount excessively debited from the Electronic Credit Ledger Account - Pre-deposit before filing of appeal - Since it is not in dispute that the petitioner has complied with the provisions laid down in Section 107(6)(b) of the CGST Act, it necessarily follows that the recovery proceedings for the balance amount shall be deemed to be stayed - the interest of the revenue has been well protected in the manner as specifically provided in the statute. This Court is thus of the considered view that the concerned respondent authority should be directed to restore back the amount which was debited from the electronic credit ledger account of the petitioner - HC
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