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 determined that supplies by petitioner outside customs frontiers qualify as zero-rated under Section 16 of IGST Act, rendering the transaction GST-exempt. The court found the tax treatment revenue neutral, particularly for the period before 01.04.2021, and declined revenue's challenge. The third-party refund application must be processed within four weeks, including applicable interest, effectively disposing of the appeal without substantial monetary implications for either party.
HC determined that supplies by petitioner outside customs frontiers qualify as zero-rated under Section 16 of IGST Act, rendering the transaction GST-exempt. The court found the tax treatment revenue neutral, particularly for the period before 01.04.2021, and declined revenue's challenge. The third-party refund application must be processed within four weeks, including applicable interest, effectively disposing of the appeal without substantial monetary implications for either party.
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