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...
The HC set aside the impugned order rejecting the petitioner's refund claim of unutilized input tax credit for zero-rated exports, holding the rejection unsustainable where shipping bills dated from 13 Sept 2021 and customs records corroborated export transactions despite the LUT being filed on 26 Aug 2021. The court directed the respondent to process and credit the petitioner's refund with statutory interest within two weeks, and further ordered that if the refund is not credited by 3 Sept 2025, interest at 12% per annum shall be payable to the petitioner. Petition allowed; impugned order dated 14 Nov 2024 quashed.
The HC set aside the impugned order rejecting the petitioner's refund claim of unutilized input tax credit for zero-rated exports, holding the rejection unsustainable where shipping bills dated from 13 Sept 2021 and customs records corroborated export transactions despite the LUT being filed on 26 Aug 2021. The court directed the respondent to process and credit the petitioner's refund with statutory interest within two weeks, and further ordered that if the refund is not credited by 3 Sept 2025, interest at 12% per annum shall be payable to the petitioner. Petition allowed; impugned order dated 14 Nov 2024 quashed.
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