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...
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Export valuation requires contemporaneous evidence; unrelated invoices cannot prove overvaluation, and dual penalties on firm and partner are impermis...
Applicability of Circular No.224/18/2024-GST para 6 turns on two preconditions: deposit of the pre-deposit contemplated under Section 112 and provision of an undertaking/intimation to the proper appellate authority. The court accepted that the taxpayer furnished the required intimation and, in the peculiar facts, treated that intimation as sufficient for para 6; accordingly the revenue was directed to refund amounts recovered under the summary demand after withholding the pre-deposit amount as contemplated under Section 112. The taxpayer forewent any claim to interest on the refunded amount.
Applicability of Circular No.224/18/2024-GST para 6 turns on two preconditions: deposit of the pre-deposit contemplated under Section 112 and provision of an undertaking/intimation to the proper appellate authority. The court accepted that the taxpayer furnished the required intimation and, in the peculiar facts, treated that intimation as sufficient for para 6; accordingly the revenue was directed to refund amounts recovered under the summary demand after withholding the pre-deposit amount as contemplated under Section 112. The taxpayer forewent any claim to interest on the refunded amount.
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