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...
A notification changing the import policy for goods under CTH 7113 from "Free" to "Restricted" took effect only on publication in the e-Official Gazette, and the exact time of electronic publication was legally material. Consignments that had already been dispatched and had arrived in India before that publication could not be subjected to the later restriction, because subordinate legislation under the foreign trade regime operates prospectively. Since the last consignment had reached the port before the notification was published, the earlier import policy governed, and the authorities were directed to clear and release the goods.
A notification changing the import policy for goods under CTH 7113 from "Free" to "Restricted" took effect only on publication in the e-Official Gazette, and the exact time of electronic publication was legally material. Consignments that had already been dispatched and had arrived in India before that publication could not be subjected to the later restriction, because subordinate legislation under the foreign trade regime operates prospectively. Since the last consignment had reached the port before the notification was published, the earlier import policy governed, and the authorities were directed to clear and release the goods.
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