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...
Entitlement to interest on IGST refund - In refund application petitioner has only claimed the integrated tax and not the interest on the same - The High court referred to Section 56 of the CGST/DGST Act and circular issued by CBEC, which mandates interest payment if refunds are not granted within 60 days from the date of application. - The court concluded that interest under Section 56 is mandatory and automatically payable if refunds are not granted within the stipulated period, irrespective of the claim made by the petitioner in the refund application.
Entitlement to interest on IGST refund - In refund application petitioner has only claimed the integrated tax and not the interest on the same - The High court referred to Section 56 of the CGST/DGST Act and circular issued by CBEC, which mandates interest payment if refunds are not granted within 60 days from the date of application. - The court concluded that interest under Section 56 is mandatory and automatically payable if refunds are not granted within the stipulated period, irrespective of the claim made by the petitioner in the refund application.
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