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 - export of service - zero rated supply - receipt in convertible foreign exchange - Amount received through Paypal in Indian currency - The High Court observed that payments received through PayPal, acting as an intermediary, and credited in Indian Rupees after conversion, complied with the FEMA regulations and RBI guidelines. - The court determined that the failure to directly receive payments in foreign currency or produce export invoices does not automatically disqualify the petitioner from refund eligibility, as the essence of the transactions met the criteria for "export of service". - Consequently, the petitioner is entitled for export of tax paid on export and the unutilized input tax credit used in export of service. - Refund allowed.
Refund claim - export of service - zero rated supply - receipt in convertible foreign exchange - Amount received through Paypal in Indian currency - The High Court observed that payments received through PayPal, acting as an intermediary, and credited in Indian Rupees after conversion, complied with the FEMA regulations and RBI guidelines. - The court determined that the failure to directly receive payments in foreign currency or produce export invoices does not automatically disqualify the petitioner from refund eligibility, as the essence of the transactions met the criteria for "export of service". - Consequently, the petitioner is entitled for export of tax paid on export and the unutilized input tax credit used in export of service. - Refund allowed.
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