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...
Bluetooth-enabled wireless headsets, earphones, earbuds and neckbands were held classifiable as transmission or reception apparatus under CTH 85176290 because their essential character and principal function was to receive, convert and transmit voice and data in a wireless network, not merely to carry audio signals. The Tribunal relied on Board Circular No. 36/2013-Cus. and prior CESTAT reasoning to treat such devices as active parts of a wireless network, while headphones with only audio functionality remain under heading 8518. The reclassification under CTH 85183000 was set aside, and the consequential duty demand based on that classification did not survive.
Bluetooth-enabled wireless headsets, earphones, earbuds and neckbands were held classifiable as transmission or reception apparatus under CTH 85176290 because their essential character and principal function was to receive, convert and transmit voice and data in a wireless network, not merely to carry audio signals. The Tribunal relied on Board Circular No. 36/2013-Cus. and prior CESTAT reasoning to treat such devices as active parts of a wireless network, while headphones with only audio functionality remain under heading 8518. The reclassification under CTH 85183000 was set aside, and the consequential duty demand based on that classification did not survive.
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