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...
Provisional release of seized imported Multi-Functional Devices was directed subject to payment of the enhanced duty as quantified, furnishing a bank guarantee for 10% of the total price, and maintenance of transaction details if the goods were later sold. HC treated the matter as comparable to earlier petitions where conditional release had been ordered, and left customs adjudication to proceed independently on merits. Any request for waiver of demurrage was to be considered objectively, and the adjudicating authority was to decide uninfluenced by the interim release.
Provisional release of seized imported Multi-Functional Devices was directed subject to payment of the enhanced duty as quantified, furnishing a bank guarantee for 10% of the total price, and maintenance of transaction details if the goods were later sold. HC treated the matter as comparable to earlier petitions where conditional release had been ordered, and left customs adjudication to proceed independently on merits. Any request for waiver of demurrage was to be considered objectively, and the adjudicating authority was to decide uninfluenced by the interim release.
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