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...
Respondent passed on the benefit of additional input tax credit to home-buyers, satisfying the anti-profiteering obligation by providing a commensurate reduction in price; the investigative report acknowledged this pass-through except for a residual payment owed to seven buyers, which the respondent agreed to remit. The tribunal accepted the investigative findings and concluded that the respondent complied with the statutory obligation to transfer GST-related ITC benefits to customers, resulting in disposal of the proceedings.
Respondent passed on the benefit of additional input tax credit to home-buyers, satisfying the anti-profiteering obligation by providing a commensurate reduction in price; the investigative report acknowledged this pass-through except for a residual payment owed to seven buyers, which the respondent agreed to remit. The tribunal accepted the investigative findings and concluded that the respondent complied with the statutory obligation to transfer GST-related ITC benefits to customers, resulting in disposal of the proceedings.
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