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...
Importers may seek part delivery of consignments where only part of the cargo has reached the CFS, by submitting an application to the Dy./Assistant Commissioner (Docks) with supporting documents. Permission is granted on merits if a container-wise packing list and proof of duty payment for the entire consignment are available; the approved application must then be uploaded in e-Sanchit, examinations must be recorded in ICES for each clearance, and final OOC is issued after the last part is examined. For short-landed containers, the IGM must be amended under the earlier simplified procedure, after which the B/E is amended, re-assessed, and sent for examination and clearance. The consolidated procedure takes immediate effect and supersedes the overlapping earlier notices.
Importers may seek part delivery of consignments where only part of the cargo has reached the CFS, by submitting an application to the Dy./Assistant Commissioner (Docks) with supporting documents. Permission is granted on merits if a container-wise packing list and proof of duty payment for the entire consignment are available; the approved application must then be uploaded in e-Sanchit, examinations must be recorded in ICES for each clearance, and final OOC is issued after the last part is examined. For short-landed containers, the IGM must be amended under the earlier simplified procedure, after which the B/E is amended, re-assessed, and sent for examination and clearance. The consolidated procedure takes immediate effect and supersedes the overlapping earlier notices.
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