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...
SEZ units may avail concessional duty for sales to DTA under the SEZ Relief Window 2026 if they apply to the jurisdictional Development Commissioner and obtain a certificate confirming eligibility, including commencement of production on or before 31 March 2025 and compliance with the notification conditions. The SEZ officer must upload certificate particulars in ICEGATE, after which the unit may file an M-type Bill of Entry without IGM or bond details. Assessment is to be done by FAG, with the CERT ledger auto-generated at 30% of the highest FOB value of the last three years and debited on assessment. The unit must make specified declarations, including minimum 20% value addition and liability to pay duty with interest if conditions are breached.
SEZ units may avail concessional duty for sales to DTA under the SEZ Relief Window 2026 if they apply to the jurisdictional Development Commissioner and obtain a certificate confirming eligibility, including commencement of production on or before 31 March 2025 and compliance with the notification conditions. The SEZ officer must upload certificate particulars in ICEGATE, after which the unit may file an M-type Bill of Entry without IGM or bond details. Assessment is to be done by FAG, with the CERT ledger auto-generated at 30% of the highest FOB value of the last three years and debited on assessment. The unit must make specified declarations, including minimum 20% value addition and liability to pay duty with interest if conditions are breached.
Note: It is a system-generated summary and is for quick reference only.
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