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 on pre-deposit requirements for tax credit appeal. The petitioner was directed to submit Form DRC-03A to the Adjudicating Authority, demonstrating prior tax credit deposit. The authority must issue confirmation within one month, which can then be used as pre-deposit evidence for filing an appeal before the Commissioner (Appeals) challenging the original order. The court effectively provided a procedural mechanism for the petitioner to validate and utilize existing tax credit deposits in the appellate process. Petition was disposed of with specific procedural instructions.
HC ruled on pre-deposit requirements for tax credit appeal. The petitioner was directed to submit Form DRC-03A to the Adjudicating Authority, demonstrating prior tax credit deposit. The authority must issue confirmation within one month, which can then be used as pre-deposit evidence for filing an appeal before the Commissioner (Appeals) challenging the original order. The court effectively provided a procedural mechanism for the petitioner to validate and utilize existing tax credit deposits in the appellate process. Petition was disposed of with specific procedural instructions.
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