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...
Doctrine of promissory estoppel - Benefit under incentive Scheme - Scenarios of new Acts replacing the VAT Act, ensuring entitlement despite the GST regime. - The High court found that the petitioner fulfilled conditions of the scheme and was entitled to benefits. Past disbursements under the scheme, including GST components, supported this entitlement. The respondent's refusal to disburse the rest of the amount was unjustified. - Clause 19.2 of the scheme was interpreted to cover scenarios where the VAT Act is replaced by any other Act, ensuring continued entitlement despite changes in taxation regimes. The court rejected the respondent's argument that the GST Act replaced multiple statutes, holding that only the VAT Act was specifically mentioned in Clause 19.2.
Doctrine of promissory estoppel - Benefit under incentive Scheme - Scenarios of new Acts replacing the VAT Act, ensuring entitlement despite the GST regime. - The High court found that the petitioner fulfilled conditions of the scheme and was entitled to benefits. Past disbursements under the scheme, including GST components, supported this entitlement. The respondent's refusal to disburse the rest of the amount was unjustified. - Clause 19.2 of the scheme was interpreted to cover scenarios where the VAT Act is replaced by any other Act, ensuring continued entitlement despite changes in taxation regimes. The court rejected the respondent's argument that the GST Act replaced multiple statutes, holding that only the VAT Act was specifically mentioned in Clause 19.2.
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