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...
Self-assessment under customs law may be corrected through amendment of a bill of entry where the importer shows an inadvertent misclassification supported by contemporaneous documentary evidence. The Tribunal noted that self-assessment is an assessment, but correction is not confined to the appellate route; amendment and correction powers can be invoked for accidental slips or omissions after clearance. A request made shortly after filing bills of entry was therefore capable of consideration under the statutory amendment and correction provisions, and rejection solely because no appeal had been filed was unsustainable. The impugned order was set aside and relief followed as per law.
Self-assessment under customs law may be corrected through amendment of a bill of entry where the importer shows an inadvertent misclassification supported by contemporaneous documentary evidence. The Tribunal noted that self-assessment is an assessment, but correction is not confined to the appellate route; amendment and correction powers can be invoked for accidental slips or omissions after clearance. A request made shortly after filing bills of entry was therefore capable of consideration under the statutory amendment and correction provisions, and rejection solely because no appeal had been filed was unsustainable. The impugned order was set aside and relief followed as per law.
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