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...
Rejection of the refund application - rejection on the ground of time limitation - Defective refund application - The High Court held that, even assuming that the petitioner subsequently submitted the relevant documents, it could not have been held that the petitioner’s application was barred by limitation, as filing of the application was not in dispute and any deficiency noted thereafter was a curable defect which could not have affected the date on which such application was filed and which was within its prescribed limitation. - HC directed the GST authorities to consider the refund application on merit.
Rejection of the refund application - rejection on the ground of time limitation - Defective refund application - The High Court held that, even assuming that the petitioner subsequently submitted the relevant documents, it could not have been held that the petitioner’s application was barred by limitation, as filing of the application was not in dispute and any deficiency noted thereafter was a curable defect which could not have affected the date on which such application was filed and which was within its prescribed limitation. - HC directed the GST authorities to consider the refund application on merit.
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