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...
Interest subvention support under the Export Promotion Mission is clarified to address cases where UIN generation lagged behind disbursal of eligible pre- or post-shipment export credit. For FY 2025-26, claims may be filed where credit was disbursed on or after 02.01.2026 and the UIN is generated on or before 31.05.2026; subvention is admissible from the date of disbursal, not from UIN generation. From FY 2026-27 onwards, a UIN generated within 15 days of original disbursal remains valid for subvention, which also runs from disbursal. Banks must apply the rate prevailing on the loan disbursal date, and claims must be linked to the relevant year of disbursal.
Interest subvention support under the Export Promotion Mission is clarified to address cases where UIN generation lagged behind disbursal of eligible pre- or post-shipment export credit. For FY 2025-26, claims may be filed where credit was disbursed on or after 02.01.2026 and the UIN is generated on or before 31.05.2026; subvention is admissible from the date of disbursal, not from UIN generation. From FY 2026-27 onwards, a UIN generated within 15 days of original disbursal remains valid for subvention, which also runs from disbursal. Banks must apply the rate prevailing on the loan disbursal date, and claims must be linked to the relevant year of disbursal.
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