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 ruled in favor of the petitioner regarding PPSB bed sheets classification, finding the Appellate Authority erroneously misinterpreted statutory provisions. The court determined that PPSB bed sheets should be taxed at 5% under Chapter 6304, not 12% under Chapter 5603. The HC directed respondents to process the petitioner's refund applications within 12 weeks, including applicable statutory interest, and modified the previous orders that incorrectly classified the bed sheets. The writ petitions were disposed of, effectively overturning the Appellate Authority's previous decisions.
HC ruled in favor of the petitioner regarding PPSB bed sheets classification, finding the Appellate Authority erroneously misinterpreted statutory provisions. The court determined that PPSB bed sheets should be taxed at 5% under Chapter 6304, not 12% under Chapter 5603. The HC directed respondents to process the petitioner's refund applications within 12 weeks, including applicable statutory interest, and modified the previous orders that incorrectly classified the bed sheets. The writ petitions were disposed of, effectively overturning the Appellate Authority's previous decisions.
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