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 AT accepted the DGAP report in part, finding that the respondent had profiteered Rs. 6,88,770 for the period 27.07.2018-31.10.2018 and directed the respondent to deposit that profiteered amount into the Consumer Welfare Fund, to be apportioned equally between the Centre and States. The Tribunal held that the statutory provision imposing interest at 18% on profiteered amounts is not applicable retrospectively; it operates only from the date the amending rule came into force (post-28.06.2019), and therefore, because the profiteering occurred prior thereto, the respondent was not directed to pay interest. The application was disposed of accordingly.
The AT accepted the DGAP report in part, finding that the respondent had profiteered Rs. 6,88,770 for the period 27.07.2018-31.10.2018 and directed the respondent to deposit that profiteered amount into the Consumer Welfare Fund, to be apportioned equally between the Centre and States. The Tribunal held that the statutory provision imposing interest at 18% on profiteered amounts is not applicable retrospectively; it operates only from the date the amending rule came into force (post-28.06.2019), and therefore, because the profiteering occurred prior thereto, the respondent was not directed to pay interest. The application was disposed of accordingly.
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