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...
The Punjab and Haryana High Court granted sales tax exemption to the petitioner in accordance with the "Special Package of Incentives to Information Technology Industry, 2000" without imposing any additional conditions. The court held that the State Government cannot deny benefits available under the Industrial Incentive Policy itself. The condition imposed in the Amendment Rules regarding the effective date was struck down. The order withdrawing the exemption was quashed, and the exemption certificate granted to the petitioner was ordered to be reinstated. The petition was allowed.
The Punjab and Haryana High Court granted sales tax exemption to the petitioner in accordance with the "Special Package of Incentives to Information Technology Industry, 2000" without imposing any additional conditions. The court held that the State Government cannot deny benefits available under the Industrial Incentive Policy itself. The condition imposed in the Amendment Rules regarding the effective date was struck down. The order withdrawing the exemption was quashed, and the exemption certificate granted to the petitioner was ordered to be reinstated. The petition was allowed.
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