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...
Impugned award unaffected by fraud or corruption; Arbitral Tribunal considered materials and submissions; no case made out regarding fraud in passing award. Parties contemplated GST implementation in Share Purchase Agreement; incentives payable only to extent tax accrued to State Government. Withdrawal of exemption notification pursuant to statutory mandate under CGST Act; legislature incorporated proviso allowing rescission of tax exemption incentives. Claim of estoppel rejected. Petitioners failed to make out prima facie case for unconditional stay; directed to secure awarded amount - 50% by transfer, 50% by bank guarantee within six weeks.
Impugned award unaffected by fraud or corruption; Arbitral Tribunal considered materials and submissions; no case made out regarding fraud in passing award. Parties contemplated GST implementation in Share Purchase Agreement; incentives payable only to extent tax accrued to State Government. Withdrawal of exemption notification pursuant to statutory mandate under CGST Act; legislature incorporated proviso allowing rescission of tax exemption incentives. Claim of estoppel rejected. Petitioners failed to make out prima facie case for unconditional stay; directed to secure awarded amount - 50% by transfer, 50% by bank guarantee within six weeks.
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