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...
Re-quantification of interest (on the refund of the pre-deposit) payment to the appellant - relevant time - The Tribunal focused on the applicable legal provisions, specifically Section 35FF of the Central Excise Act, 1944, as amended. It noted that the pre-deposit was made before the amendment of this section, and therefore, the provisions applicable at the time of the deposit govern the interest calculations. The Tribunal upheld the view that interest is payable only after three months from the date of the appellate order, as per the unamended Section 35FF.
Re-quantification of interest (on the refund of the pre-deposit) payment to the appellant - relevant time - The Tribunal focused on the applicable legal provisions, specifically Section 35FF of the Central Excise Act, 1944, as amended. It noted that the pre-deposit was made before the amendment of this section, and therefore, the provisions applicable at the time of the deposit govern the interest calculations. The Tribunal upheld the view that interest is payable only after three months from the date of the appellate order, as per the unamended Section 35FF.
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