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 dated 31 January 2025 and allowed the petition by way of remand. The court addressed an appeal concerning invocation of the extended period of limitation and prior reversal of input tax credit appropriation, noting the Revenue's failure to produce documentary proof of foreign exchange realization such as BRCs or FIRCs. The HC held that FIRCs need not correspond transaction-by-transaction and may be maintained on a periodic basis, provided the aggregate foreign exchange remitted fully substantiates the claimed benefit. The matter is remitted for fresh consideration in accordance with this principle and applicable law, with liberty to both parties to lead relevant evidence.
The HC set aside the impugned order dated 31 January 2025 and allowed the petition by way of remand. The court addressed an appeal concerning invocation of the extended period of limitation and prior reversal of input tax credit appropriation, noting the Revenue's failure to produce documentary proof of foreign exchange realization such as BRCs or FIRCs. The HC held that FIRCs need not correspond transaction-by-transaction and may be maintained on a periodic basis, provided the aggregate foreign exchange remitted fully substantiates the claimed benefit. The matter is remitted for fresh consideration in accordance with this principle and applicable law, with liberty to both parties to lead relevant evidence.
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