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...
Brake hoses for two-wheelers and four-wheelers were treated as tubes, pipes and hoses of vulcanised rubber under Heading 4009 because the rubber component gave the goods their essential character under GRI 3(b). Steel fittings and automotive braking use did not change their classification, as Heading 4009 covers hoses with or without fittings. Section XVII vehicle-part classification was rejected because the conditions for applying those notes were not satisfied and the goods were more specifically covered elsewhere. The prior classification under Chapter 87 was set aside, and the applicable GST rate was held to be 18%.
Brake hoses for two-wheelers and four-wheelers were treated as tubes, pipes and hoses of vulcanised rubber under Heading 4009 because the rubber component gave the goods their essential character under GRI 3(b). Steel fittings and automotive braking use did not change their classification, as Heading 4009 covers hoses with or without fittings. Section XVII vehicle-part classification was rejected because the conditions for applying those notes were not satisfied and the goods were more specifically covered elsewhere. The prior classification under Chapter 87 was set aside, and the applicable GST rate was held to be 18%.
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