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 dismissed contempt proceedings against respondents 5 and 6 after accepting their uncontroverted explanations in show cause responses, as petitioner filed no rejoinder. Court found illegal recovery by State respondents and directed refund with 9% per annum simple interest from recovery date until refund date, payable within six weeks. State respondents ordered to pay Rs. 10,000 costs to petitioner within same timeframe due to illegal recovery causing litigation. Writ application disposed of with directions for monetary relief and interest compensation to petitioner.
HC dismissed contempt proceedings against respondents 5 and 6 after accepting their uncontroverted explanations in show cause responses, as petitioner filed no rejoinder. Court found illegal recovery by State respondents and directed refund with 9% per annum simple interest from recovery date until refund date, payable within six weeks. State respondents ordered to pay Rs. 10,000 costs to petitioner within same timeframe due to illegal recovery causing litigation. Writ application disposed of with directions for monetary relief and interest compensation to petitioner.
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