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...
Petitioner alleges compliance with pre-deposit obligations at two appellate stages and seeks relief from recovery; court directed petitioner to make representation to GST authorities proving payment and allowed authorities to verify and call for clarifications. Any sum recovered in excess of the cumulative deposits required at the two appellate stages must be refunded. Court did not determine merits and left substantive decision to the GST authorities, who may examine evidence and take an informed decision on refund and stay-related consequences.
Petitioner alleges compliance with pre-deposit obligations at two appellate stages and seeks relief from recovery; court directed petitioner to make representation to GST authorities proving payment and allowed authorities to verify and call for clarifications. Any sum recovered in excess of the cumulative deposits required at the two appellate stages must be refunded. Court did not determine merits and left substantive decision to the GST authorities, who may examine evidence and take an informed decision on refund and stay-related consequences.
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