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...
Imported scrap valuation was discussed in the context of reassessment based on NIDB data and contemporaneous imports. The Tribunal applied its earlier ruling, following the Delhi High Court view, that enhancement of declared value cannot rest solely on such data without legally sufficient justification under the valuation scheme, and that payment of enhanced duty to obtain clearance does not prevent the importer from challenging the reassessment in appeal. On that basis, the impugned order was held unsustainable and the appeals were allowed with consequential relief.
Imported scrap valuation was discussed in the context of reassessment based on NIDB data and contemporaneous imports. The Tribunal applied its earlier ruling, following the Delhi High Court view, that enhancement of declared value cannot rest solely on such data without legally sufficient justification under the valuation scheme, and that payment of enhanced duty to obtain clearance does not prevent the importer from challenging the reassessment in appeal. On that basis, the impugned order was held unsustainable and the appeals were allowed with consequential relief.
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