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...
Customs field formations are directed not to seek direct clarification from DGFT Headquarters or Regional Authorities on interpretation of FTP provisions or policy conditions. Such issues must first be examined at Commissionerate/Zonal level, and only policy-level matters after due examination may be referred to the Board by the concerned Principal Chief Commissioner/Chief Commissioner; commodity-specific issues require prior examination and approval by the concerned National Assessment Centre. Every reference must include concise facts, the provision in question, the field interpretation, the specific point needing clarification, the number of affected cases, whether live consignments are pending, and urgency status. Pending consignments should not be kept on hold solely for interpretational issues, and provisional assessment or other facilitative mechanisms may be used where legally permissible.
Customs field formations are directed not to seek direct clarification from DGFT Headquarters or Regional Authorities on interpretation of FTP provisions or policy conditions. Such issues must first be examined at Commissionerate/Zonal level, and only policy-level matters after due examination may be referred to the Board by the concerned Principal Chief Commissioner/Chief Commissioner; commodity-specific issues require prior examination and approval by the concerned National Assessment Centre. Every reference must include concise facts, the provision in question, the field interpretation, the specific point needing clarification, the number of affected cases, whether live consignments are pending, and urgency status. Pending consignments should not be kept on hold solely for interpretational issues, and provisional assessment or other facilitative mechanisms may be used where legally permissible.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4805
Join Channel
TaxTMI 
