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 refund claim challenging rejection based on non-submission of documents. The court held that proof of payment is not mandatory for export of goods, and only reconciliation statement of Shipping Bill and Export Invoices is required. The RBI circular stipulates payment realization within 9 months, which was satisfied in this case. The order rejecting refund was deemed unsustainable as it was based on grounds beyond CGST Act & Rules, effectively invalidating the original administrative decision and granting relief to the petitioner.
HC allowed refund claim challenging rejection based on non-submission of documents. The court held that proof of payment is not mandatory for export of goods, and only reconciliation statement of Shipping Bill and Export Invoices is required. The RBI circular stipulates payment realization within 9 months, which was satisfied in this case. The order rejecting refund was deemed unsustainable as it was based on grounds beyond CGST Act & Rules, effectively invalidating the original administrative decision and granting relief to the petitioner.
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