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...
A taxpayer showing prima facie prior payment of the same tax amount was entitled to place proof before the proper officer through a rectification application before any recovery action was taken. Where the revenue could not dispute that the receipt corresponded to the amount later treated as short-paid, the court directed verification in accordance with law to avoid double recovery of tax already paid. The petitioner was permitted to file the rectification application within the time granted, and the proper officer was required to consider it within a reasonable period.
A taxpayer showing prima facie prior payment of the same tax amount was entitled to place proof before the proper officer through a rectification application before any recovery action was taken. Where the revenue could not dispute that the receipt corresponded to the amount later treated as short-paid, the court directed verification in accordance with law to avoid double recovery of tax already paid. The petitioner was permitted to file the rectification application within the time granted, and the proper officer was required to consider it within a reasonable period.
Note: It is a system-generated summary and is for quick reference only.