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...
Food testing kits were held classifiable under CTI 3822 00 90, not CTI 3822 00 19, because they were meant for food testing and not diagnostic use; the importer's claim to exemption under Notification No. 50/2017-Cus for diagnostic test kits therefore failed. The Tribunal also held that describing the goods as "Diagnostic use only" in self-assessment amounted to conscious misdeclaration, justifying invocation of the extended period of limitation. On that basis, the penalties imposed on the importer and its directors were upheld, and the impugned order was sustained in full.
Food testing kits were held classifiable under CTI 3822 00 90, not CTI 3822 00 19, because they were meant for food testing and not diagnostic use; the importer's claim to exemption under Notification No. 50/2017-Cus for diagnostic test kits therefore failed. The Tribunal also held that describing the goods as "Diagnostic use only" in self-assessment amounted to conscious misdeclaration, justifying invocation of the extended period of limitation. On that basis, the penalties imposed on the importer and its directors were upheld, and the impugned order was sustained in full.
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