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 quashed deficiency memo dated 21.02.2024 regarding CESS refund claim for AY 2017-18. Petitioner claimed clerical error in placing SGST figures in CESS column. While authority has discretion on refund eligibility under Section 39(9) and 54(1) of Act 2017, rejection requires reasoned order uploaded to portal enabling appeal rights. Court directed authority to reconsider refund application dated 05.02.2024 after providing hearing opportunity, pass reasoned order, and upload promptly to relevant portal. Matter concerns procedural compliance rather than substantive refund determination. Authority must follow due process in handling correction requests within statutory timeframes.
HC quashed deficiency memo dated 21.02.2024 regarding CESS refund claim for AY 2017-18. Petitioner claimed clerical error in placing SGST figures in CESS column. While authority has discretion on refund eligibility under Section 39(9) and 54(1) of Act 2017, rejection requires reasoned order uploaded to portal enabling appeal rights. Court directed authority to reconsider refund application dated 05.02.2024 after providing hearing opportunity, pass reasoned order, and upload promptly to relevant portal. Matter concerns procedural compliance rather than substantive refund determination. Authority must follow due process in handling correction requests within statutory timeframes.
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