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...
HC held that u/s 54 of CGST Act, 2017, failure to process IGST refund claim for goods exported is impermissible. Shipping Bill serves as refund application. Proper officer must issue order within 60 days of complete application. Circulars fix responsibility on officers and agents, not exporters. Refund must be allowed or rejected with reasons. Respondent directed to process and sanction Rs. 2,44,61,247 IGST refund within 4 weeks. Petition allowed.
HC held that u/s 54 of CGST Act, 2017, failure to process IGST refund claim for goods exported is impermissible. Shipping Bill serves as refund application. Proper officer must issue order within 60 days of complete application. Circulars fix responsibility on officers and agents, not exporters. Refund must be allowed or rejected with reasons. Respondent directed to process and sanction Rs. 2,44,61,247 IGST refund within 4 weeks. Petition allowed.
Note: It is a system-generated summary and is for quick reference only.