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 allowed the petitioner's refund claim, quashing the respondent's rejection order. The court directed the respondent to grant a refund of Rs. 96,65,325/- with 6% interest per annum from 12.09.2021 until actual payment, as per Section 56 of CGST Act. The original ground for refund rejection was found factually incorrect, as the Appellate Authority had indeed specified the refund amount. The petition was consequently disposed of in favor of the petitioner.
HC allowed the petitioner's refund claim, quashing the respondent's rejection order. The court directed the respondent to grant a refund of Rs. 96,65,325/- with 6% interest per annum from 12.09.2021 until actual payment, as per Section 56 of CGST Act. The original ground for refund rejection was found factually incorrect, as the Appellate Authority had indeed specified the refund amount. The petition was consequently disposed of in favor of the petitioner.
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