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...
Customs valuation of imported High Pressure Laminate Sheets could not be enhanced where the redetermination relied substantially on a retracted statement and invoices of alleged contemporaneous imports that were not shown to be comparable. The tribunal found no acceptable supporting evidence beyond the retracted statement, and the relied-upon invoice described different goods. In the absence of reliable material to reject the declared value, the enhancement was unsustainable and the impugned valuation order was set aside.
Customs valuation of imported High Pressure Laminate Sheets could not be enhanced where the redetermination relied substantially on a retracted statement and invoices of alleged contemporaneous imports that were not shown to be comparable. The tribunal found no acceptable supporting evidence beyond the retracted statement, and the relied-upon invoice described different goods. In the absence of reliable material to reject the declared value, the enhancement was unsustainable and the impugned valuation order was set aside.
Note: It is a system-generated summary and is for quick reference only.