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...
Amounts paid and collected under protest during the period of disputed tax liability were treated as part of compliance with the statutory pre-deposit requirement, because there was no express provision excluding such deposits from consideration. The High Court noted, prima facie, that the taxpayer had already paid TCS under protest from 1 April 2021, and that those sums related to the disputed liability period but had not been included in the quantification. Rejecting the contention that the payments amounted to an admission of liability for the later period, the Court modified the earlier interim condition and held that no further 10% deposit was required for the petition to proceed on merits.
Amounts paid and collected under protest during the period of disputed tax liability were treated as part of compliance with the statutory pre-deposit requirement, because there was no express provision excluding such deposits from consideration. The High Court noted, prima facie, that the taxpayer had already paid TCS under protest from 1 April 2021, and that those sums related to the disputed liability period but had not been included in the quantification. Rejecting the contention that the payments amounted to an admission of liability for the later period, the Court modified the earlier interim condition and held that no further 10% deposit was required for the petition to proceed on merits.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4816 
Join Channel 
