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...
HC directed state authorities to process petitioner's GST refund claim promptly following verification of facts and entitlement. Decision must consider state government's order dated 10.10.2018 and subsequent relevant orders. Court acknowledged petitioner's argument that similar GST refunds were previously granted in comparable cases. State must evaluate claim in light of established precedent regarding GST refunds during contract execution. Authorities instructed to conduct thorough assessment while maintaining consistency with prior administrative decisions on GST reimbursements. Matter disposed with specific directive for immediate processing of refund application.
HC directed state authorities to process petitioner's GST refund claim promptly following verification of facts and entitlement. Decision must consider state government's order dated 10.10.2018 and subsequent relevant orders. Court acknowledged petitioner's argument that similar GST refunds were previously granted in comparable cases. State must evaluate claim in light of established precedent regarding GST refunds during contract execution. Authorities instructed to conduct thorough assessment while maintaining consistency with prior administrative decisions on GST reimbursements. Matter disposed with specific directive for immediate processing of refund application.
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