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...
Petitioner deposited amount under alleged coercion and protest, claiming inadmissible Input Tax Credit availed. Respondent disputed coercion, stating voluntary deposit. Court observed deposits not made during raid or custody, but under alleged threat of cancellation of registration. Petitioner could have availed remedies against such threats. Court deemed enquiry into coercion or voluntary deposit unnecessary, noting petitioner can seek refund if excess tax deposited, in accordance with law. Petition disposed of.
Petitioner deposited amount under alleged coercion and protest, claiming inadmissible Input Tax Credit availed. Respondent disputed coercion, stating voluntary deposit. Court observed deposits not made during raid or custody, but under alleged threat of cancellation of registration. Petitioner could have availed remedies against such threats. Court deemed enquiry into coercion or voluntary deposit unnecessary, noting petitioner can seek refund if excess tax deposited, in accordance with law. Petition disposed of.
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