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...
Refund money deposited in Court could not be retained once the Department's challenge had been relegated to the statutory appeal before the Tribunal and no interim restraint was operating there. The High Court noted that the earlier order had not been adjudicated on merits, and in the absence of any Tribunal order preventing release, the deposited amount had to be returned to the petitioner. The release was directed to be made subject to any further orders passed in the Department's pending appeal before the Tribunal.
Refund money deposited in Court could not be retained once the Department's challenge had been relegated to the statutory appeal before the Tribunal and no interim restraint was operating there. The High Court noted that the earlier order had not been adjudicated on merits, and in the absence of any Tribunal order preventing release, the deposited amount had to be returned to the petitioner. The release was directed to be made subject to any further orders passed in the Department's pending appeal before the Tribunal.
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