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...
Claim of Interest on Refund of pre-deposit - Rejection on the ground that the amount of interest on the refund claim as was already sanctioned to the appellant - The Appellate Tribunal holds that the appellant is entitled to interest on the refund of the pre-deposit amount. It cites various legal precedents and interpretations to support this decision. The Tribunal rejects the department's argument and affirms the appellant's entitlement to interest at a rate of 12% per annum from the date of deposit to the date of payment. - It dismisses the department's reliance on a notification from 2014 and determines the interest rate based on legal precedents and the specific circumstances of the case.
Claim of Interest on Refund of pre-deposit - Rejection on the ground that the amount of interest on the refund claim as was already sanctioned to the appellant - The Appellate Tribunal holds that the appellant is entitled to interest on the refund of the pre-deposit amount. It cites various legal precedents and interpretations to support this decision. The Tribunal rejects the department's argument and affirms the appellant's entitlement to interest at a rate of 12% per annum from the date of deposit to the date of payment. - It dismisses the department's reliance on a notification from 2014 and determines the interest rate based on legal precedents and the specific circumstances of the case.
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