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...
Manner of payment of Pre-deposit amount before filing of appeal against demand of service tax - Admissibility of payment of pre-deposit using DRC-03 - The appellant argued that they had deposited the pre-deposit using the input tax credit available in their DRC-03 under CGST regime. - Considering the absence of a specific provision allowing pre-deposit via DRC-03, the Tribunal rejected the appellant's argument and relied on various judicial precedents to affirm that such a method was not permissible under Section 35F.
Manner of payment of Pre-deposit amount before filing of appeal against demand of service tax - Admissibility of payment of pre-deposit using DRC-03 - The appellant argued that they had deposited the pre-deposit using the input tax credit available in their DRC-03 under CGST regime. - Considering the absence of a specific provision allowing pre-deposit via DRC-03, the Tribunal rejected the appellant's argument and relied on various judicial precedents to affirm that such a method was not permissible under Section 35F.
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