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...
Import restriction notifications become enforceable only upon publication in the prescribed e-Official Gazette, and the exact time of publication is legally significant where consignments have already arrived. Absent an enabling power for retrospective operation, subordinate legislation applies prospectively and cannot govern goods that landed before the notification came into force; those imports remain subject to the prior free regime. A separate challenge to the notification is not required when relief depends only on its non-application to the facts. On that basis, the goods were directed to be processed for release under the earlier legal position.
Import restriction notifications become enforceable only upon publication in the prescribed e-Official Gazette, and the exact time of publication is legally significant where consignments have already arrived. Absent an enabling power for retrospective operation, subordinate legislation applies prospectively and cannot govern goods that landed before the notification came into force; those imports remain subject to the prior free regime. A separate challenge to the notification is not required when relief depends only on its non-application to the facts. On that basis, the goods were directed to be processed for release under the earlier legal position.
Note: It is a system-generated summary and is for quick reference only.