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...
Refund of Excess Customs Duty paid - principles of unjust enrichment - Following proceedings before the Settlement Commission, it was determined that the appellant had indeed overpaid, resulting in an excess amount of refund. The Tribunal upheld the appellant's right to claim the refund, considering the terms of the agreement with their overseas supplier, the treatment of the amount in their accounting records, and legal precedents supporting their case. - The Tribunal concluded that the appellant was entitled to the refund of the excess amount, as they had not passed on the duty burden and had treated it as receivable in their accounts.
Refund of Excess Customs Duty paid - principles of unjust enrichment - Following proceedings before the Settlement Commission, it was determined that the appellant had indeed overpaid, resulting in an excess amount of refund. The Tribunal upheld the appellant's right to claim the refund, considering the terms of the agreement with their overseas supplier, the treatment of the amount in their accounting records, and legal precedents supporting their case. - The Tribunal concluded that the appellant was entitled to the refund of the excess amount, as they had not passed on the duty burden and had treated it as receivable in their accounts.
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