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...
Rejection of an IGST refund was set aside because the authority failed to apply its mind and breached principles of natural justice by not addressing the petitioner's contentions and contractual arrangements on whether the services were exports or intermediary services; the Court identified need to examine agreements and relevant precedents/circulars and directed remand for de novo consideration after hearing the parties. Outcome: the impugned order was quashed and the matter returned for fresh determination of the export-versus-intermediary question with all contentions open and a three-month timeline for decision.
Rejection of an IGST refund was set aside because the authority failed to apply its mind and breached principles of natural justice by not addressing the petitioner's contentions and contractual arrangements on whether the services were exports or intermediary services; the Court identified need to examine agreements and relevant precedents/circulars and directed remand for de novo consideration after hearing the parties. Outcome: the impugned order was quashed and the matter returned for fresh determination of the export-versus-intermediary question with all contentions open and a three-month timeline for decision.
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