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...
Interest claim for refund of amount deposited under protest was denied as the refund applications were processed within a month of receipt, falling within the three-month grace period u/ss 11BB and 35FF of the Central Excise Act, 1944. The appellant was not entitled to interest from the date of deposit due to the proviso in Section 35FF for amounts deposited prior to the Finance (No. 2) Act, 2014. The appeals were dismissed by the Appellate Tribunal.
Interest claim for refund of amount deposited under protest was denied as the refund applications were processed within a month of receipt, falling within the three-month grace period u/ss 11BB and 35FF of the Central Excise Act, 1944. The appellant was not entitled to interest from the date of deposit due to the proviso in Section 35FF for amounts deposited prior to the Finance (No. 2) Act, 2014. The appeals were dismissed by the Appellate Tribunal.
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