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...
Gold and gold jewellery seized pending adjudication may be provisionally released under Section 110A where the goods are not prohibited for import and redemption would remain available under Section 125 even on confiscation. Mere allegations in a show cause notice or investigation record are not, by themselves, enough to refuse release. On the facts, the stock register supported licit procurement and possession, so the balance of convenience favoured release. The Tribunal allowed provisional release subject to execution of a bond for the full value of the goods and a bank guarantee for 50% of the gold value with an auto-renewal clause, with release to follow within the stipulated time.
Gold and gold jewellery seized pending adjudication may be provisionally released under Section 110A where the goods are not prohibited for import and redemption would remain available under Section 125 even on confiscation. Mere allegations in a show cause notice or investigation record are not, by themselves, enough to refuse release. On the facts, the stock register supported licit procurement and possession, so the balance of convenience favoured release. The Tribunal allowed provisional release subject to execution of a bond for the full value of the goods and a bank guarantee for 50% of the gold value with an auto-renewal clause, with release to follow within the stipulated time.
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