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...
Duty Free Shops (DFS) at airports and various government authorities - Refund of amount collected by respondents No.3 and 4 (AAI) on wrongful application of CGST Act, the Integrated Goods and Service Tax Act, 2017 (the IGST Act) and PGST Act - The High Court held that the petitioner is bound to pay the GST on the Services provided by the respondents No.3 not only in accordance with the case laws discussed hereinabove but also due to the binding concession agreement between the petitioner and the respondents No.3 and 4 - The court ordered the company to reimburse a sum of Rs. 3,83,38,993 to the government authorities within four weeks, along with interest. The company was also directed to make necessary applications for claiming Input Tax Credit (ITC) and/or refund of the amount reimbursed.
Duty Free Shops (DFS) at airports and various government authorities - Refund of amount collected by respondents No.3 and 4 (AAI) on wrongful application of CGST Act, the Integrated Goods and Service Tax Act, 2017 (the IGST Act) and PGST Act - The High Court held that the petitioner is bound to pay the GST on the Services provided by the respondents No.3 not only in accordance with the case laws discussed hereinabove but also due to the binding concession agreement between the petitioner and the respondents No.3 and 4 - The court ordered the company to reimburse a sum of Rs. 3,83,38,993 to the government authorities within four weeks, along with interest. The company was also directed to make necessary applications for claiming Input Tax Credit (ITC) and/or refund of the amount reimbursed.
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