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...
Proviso to Section 68 allows an owner of warehoused goods to relinquish title at any time before an order for clearance for home consumption, and that relinquishment removes liability to customs duty unless an offence appears to have been committed. The text further states that relinquishment after issue of a show-cause notice does not by itself take away this benefit. On the stated facts, no offence under the Customs Act, 1962 was found, so the demands of duty, redemption fine and penalty were not sustainable.
Proviso to Section 68 allows an owner of warehoused goods to relinquish title at any time before an order for clearance for home consumption, and that relinquishment removes liability to customs duty unless an offence appears to have been committed. The text further states that relinquishment after issue of a show-cause notice does not by itself take away this benefit. On the stated facts, no offence under the Customs Act, 1962 was found, so the demands of duty, redemption fine and penalty were not sustainable.
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