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 - time limitation - The authorities and for that matter this Tribunal, being creatures of the statute cannot extend the period of limitation or pass an order to the effect that delayed submission of refund would not disentitled to the refund, even if it pertains to refund of duty paid, which is subsequently, held to be non-payable. - AT
Refund claim - time limitation - The authorities and for that matter this Tribunal, being creatures of the statute cannot extend the period of limitation or pass an order to the effect that delayed submission of refund would not disentitled to the refund, even if it pertains to refund of duty paid, which is subsequently, held to be non-payable. - AT
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