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...
GST budgetary support under Notification No. 20/2007 was examined in light of the 22-02-2023 clarification and the earlier coordinate Bench view on similarly situated units. The Court noted that the exemption applied to units commencing commercial production by 31-03-2017 and that the petitioner's eligibility certificate reflected commencement after modernization from 30-03-2017. As the respondents did not dispute the coordinate Bench position, the Court did not decide entitlement on merits and instead directed verification of whether the petitioner stood on the same footing as the units covered by M/s Sai Enterprises and analogous matters. If parity is confirmed, the corresponding benefits are to be extended.
GST budgetary support under Notification No. 20/2007 was examined in light of the 22-02-2023 clarification and the earlier coordinate Bench view on similarly situated units. The Court noted that the exemption applied to units commencing commercial production by 31-03-2017 and that the petitioner's eligibility certificate reflected commencement after modernization from 30-03-2017. As the respondents did not dispute the coordinate Bench position, the Court did not decide entitlement on merits and instead directed verification of whether the petitioner stood on the same footing as the units covered by M/s Sai Enterprises and analogous matters. If parity is confirmed, the corresponding benefits are to be extended.
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