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...
Re-export of seized imported goods was permitted because the goods had remained under seizure for over a year, samples had already been drawn and tested, and their continued retention served no useful purpose. The Court did not examine the merits of the allegations of misclassification, undervaluation, or breach of minimum import price conditions. As the respondents did not seriously oppose re-export, permission was granted subject to safeguards: execution of a bond for the differential duty liability and furnishing of a bank guarantee equal to 5% of the re-determined value.
Re-export of seized imported goods was permitted because the goods had remained under seizure for over a year, samples had already been drawn and tested, and their continued retention served no useful purpose. The Court did not examine the merits of the allegations of misclassification, undervaluation, or breach of minimum import price conditions. As the respondents did not seriously oppose re-export, permission was granted subject to safeguards: execution of a bond for the differential duty liability and furnishing of a bank guarantee equal to 5% of the re-determined value.
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