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 allowed the petition, setting aside the impugned order dated 09.09.2024, and directed respondents to refund the contested amount with statutory interest at 6% per annum from the date the order of the First Authority became operative, on the ground that the refund was not made within 60 days of that order. The court rejected respondents' plea to attract the higher 9% rate, noting petitioners sought only 6% and that the Appellate Authority had quashed the original rejection dated 14.09.2020. The HC held the rejection to be unlawful and confirmed entitlement to the specified interest on the delayed refund.
The HC allowed the petition, setting aside the impugned order dated 09.09.2024, and directed respondents to refund the contested amount with statutory interest at 6% per annum from the date the order of the First Authority became operative, on the ground that the refund was not made within 60 days of that order. The court rejected respondents' plea to attract the higher 9% rate, noting petitioners sought only 6% and that the Appellate Authority had quashed the original rejection dated 14.09.2020. The HC held the rejection to be unlawful and confirmed entitlement to the specified interest on the delayed refund.
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