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...
Imported parts of diesel engines and earth-moving equipment were found to fall under Customs Tariff Heading 8483, but the dispute centred on the applicable IGST entry. The Tribunal held that Notification No. 35/2017-IT(RT) specifically inserted plain shaft bearings at Sl. No. 369A in Schedule III, attracting IGST at 18%, and simultaneously omitted "plain shaft bearings" from Sl. No. 135 in Schedule IV. Because the goods matched the specific Schedule III entry, the later amendment under Notification No. 43/2017 did not apply. The lower IGST rate was therefore correctly allowed, and the Revenue's challenge failed.
Imported parts of diesel engines and earth-moving equipment were found to fall under Customs Tariff Heading 8483, but the dispute centred on the applicable IGST entry. The Tribunal held that Notification No. 35/2017-IT(RT) specifically inserted plain shaft bearings at Sl. No. 369A in Schedule III, attracting IGST at 18%, and simultaneously omitted "plain shaft bearings" from Sl. No. 135 in Schedule IV. Because the goods matched the specific Schedule III entry, the later amendment under Notification No. 43/2017 did not apply. The lower IGST rate was therefore correctly allowed, and the Revenue's challenge failed.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4807
Join Channel
TaxTMI 
