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 claim - determination of the turn over for the purpose of refund - After considering the submissions, the High Court found merit in the petitioner's argument that the issue could be re-examined in light of Circular No. 197/09/2023-GST. The court noted the clarification provided in paragraph 3 of the circular regarding the calculation of adjusted total turnover for the purpose of refund. Therefore, the High Court set aside the impugned order and remitted the case back to the respondent to pass orders afresh on merits and in accordance with law.
Refund claim - determination of the turn over for the purpose of refund - After considering the submissions, the High Court found merit in the petitioner's argument that the issue could be re-examined in light of Circular No. 197/09/2023-GST. The court noted the clarification provided in paragraph 3 of the circular regarding the calculation of adjusted total turnover for the purpose of refund. Therefore, the High Court set aside the impugned order and remitted the case back to the respondent to pass orders afresh on merits and in accordance with law.
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