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...
Failure to comply with statutory timelines for refund scrutiny means issuance of a deficiency memo after the prescribed period is impermissible, so the refund claim must be processed and allowed in accordance with the applicable acknowledgement and scrutiny rules; the prior direction to sanction refund with statutory interest therefore remains operative and requires enforcement. The writ seeking mandamus for compliance was allowed, directing the respondent to sanction the refund for the specified period together with statutory interest and to complete compliance within the time directed by the Court.
Failure to comply with statutory timelines for refund scrutiny means issuance of a deficiency memo after the prescribed period is impermissible, so the refund claim must be processed and allowed in accordance with the applicable acknowledgement and scrutiny rules; the prior direction to sanction refund with statutory interest therefore remains operative and requires enforcement. The writ seeking mandamus for compliance was allowed, directing the respondent to sanction the refund for the specified period together with statutory interest and to complete compliance within the time directed by the Court.
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