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...
100% EOU wrongly claimed refund u/r 96 instead of Rule 89 of CGST Rules, 2017 on IGST paid on inputs/capital goods utilized for exports. HC held EOU entitled to exemption u/r 89 as exports made and refund claims based on shipping bills. Procedural irregularity should not obstruct legitimate export incentives. Impugned order set aside, matter remitted to pass fresh order examining exports for granting refund u/r 89 and Section 16(3) of IGST Act, 2017.
100% EOU wrongly claimed refund u/r 96 instead of Rule 89 of CGST Rules, 2017 on IGST paid on inputs/capital goods utilized for exports. HC held EOU entitled to exemption u/r 89 as exports made and refund claims based on shipping bills. Procedural irregularity should not obstruct legitimate export incentives. Impugned order set aside, matter remitted to pass fresh order examining exports for granting refund u/r 89 and Section 16(3) of IGST Act, 2017.
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