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...
Seeking reimbursement of GST amount paid by the petitioner - Interpretation of Contract Clause - After analyzing the documents and submissions, the High Court found that the petitioner's quoted rates were indeed exclusive of GST and that the respondent had already reimbursed GST for previous bills. The court rejected the respondent's interpretation of the contract clause, stating that there was no evidence to support that it included GST. Therefore, the court directed the respondent to reimburse the GST paid by the petitioner on all bills within a specified timeframe.
Seeking reimbursement of GST amount paid by the petitioner - Interpretation of Contract Clause - After analyzing the documents and submissions, the High Court found that the petitioner's quoted rates were indeed exclusive of GST and that the respondent had already reimbursed GST for previous bills. The court rejected the respondent's interpretation of the contract clause, stating that there was no evidence to support that it included GST. Therefore, the court directed the respondent to reimburse the GST paid by the petitioner on all bills within a specified timeframe.
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