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...
Movement of goods from Maharashtra to Buffer Depots and Satellite Depots in other States was treated as stock transfer, not an inter-State sale, because the Agreement and MOU did not create a binding prior contract fixing quantity, specification or determinative price at dispatch. The concluded sales arose only at depot level on receipt and acceptance of purchase orders, and the goods moved as mixed inventory replenishment under stock transfer documents. Form F declarations for 2008-09 could not be rejected for omitting lorry receipt numbers and vehicle details where the lorry receipts themselves proved dispatch; those omissions were only minor procedural defects.
Movement of goods from Maharashtra to Buffer Depots and Satellite Depots in other States was treated as stock transfer, not an inter-State sale, because the Agreement and MOU did not create a binding prior contract fixing quantity, specification or determinative price at dispatch. The concluded sales arose only at depot level on receipt and acceptance of purchase orders, and the goods moved as mixed inventory replenishment under stock transfer documents. Form F declarations for 2008-09 could not be rejected for omitting lorry receipt numbers and vehicle details where the lorry receipts themselves proved dispatch; those omissions were only minor procedural defects.
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