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...
Alkyl Ketene Dimer (AKD Wax) was held classifiable as prepared wax under Heading 34049090, because its waxy characteristics, dropping point, viscosity, commercial identity and paper-sizing use matched Heading 3404 rather than a separate chemically defined organic compound under Chapter 29. The extended period for duty demand was not invocable, as the product had been consistently declared and accepted by Customs on the same facts, so the demand was confined to the normal period with interest. Confiscation of goods already cleared for home consumption was unsustainable, but confiscation and redemption fine on the live consignment were upheld; all penalties were set aside for lack of evidence of conscious abetment.
Alkyl Ketene Dimer (AKD Wax) was held classifiable as prepared wax under Heading 34049090, because its waxy characteristics, dropping point, viscosity, commercial identity and paper-sizing use matched Heading 3404 rather than a separate chemically defined organic compound under Chapter 29. The extended period for duty demand was not invocable, as the product had been consistently declared and accepted by Customs on the same facts, so the demand was confined to the normal period with interest. Confiscation of goods already cleared for home consumption was unsustainable, but confiscation and redemption fine on the live consignment were upheld; all penalties were set aside for lack of evidence of conscious abetment.
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