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...
Regarding processing of manual refund application, it is held that when genuine issues arise, the Department should adopt a liberal approach, particularly considering that no party would intentionally delay or fail to file refund application in the portal when substantial refund amount is due. The Department should avoid unwarranted litigation on such issues and make the system more assessee-friendly, fostering Revenue's interest in tax collection. In the given case, technicalities should not impede the assessee. The petition is disposed of.
Regarding processing of manual refund application, it is held that when genuine issues arise, the Department should adopt a liberal approach, particularly considering that no party would intentionally delay or fail to file refund application in the portal when substantial refund amount is due. The Department should avoid unwarranted litigation on such issues and make the system more assessee-friendly, fostering Revenue's interest in tax collection. In the given case, technicalities should not impede the assessee. The petition is disposed of.
Note: It is a system-generated summary and is for quick reference only.
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