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...
A central tax policy instruction directs uniform implementation permitting provisional sanction of 90% of refund claims for system-identified low-risk applications relating to zero-rated supplies, and temporarily for inverted duty structure claims, effective for claims filed on or after 01.10.2025; officers may, with reasons recorded, opt for detailed scrutiny instead of provisional grant, and certain notified categories remain ineligible for provisional refunds. Statutory conditions (including non-prosecution requirements) continue to apply; overpayments discovered on verification will prompt show-cause proceedings and recovery. Jurisdictional supervising officers must monitor implementation and report difficulties to the Board.
A central tax policy instruction directs uniform implementation permitting provisional sanction of 90% of refund claims for system-identified low-risk applications relating to zero-rated supplies, and temporarily for inverted duty structure claims, effective for claims filed on or after 01.10.2025; officers may, with reasons recorded, opt for detailed scrutiny instead of provisional grant, and certain notified categories remain ineligible for provisional refunds. Statutory conditions (including non-prosecution requirements) continue to apply; overpayments discovered on verification will prompt show-cause proceedings and recovery. Jurisdictional supervising officers must monitor implementation and report difficulties to the Board.
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