Power to receive documentary evidence upheld; documents referred in complaint may be placed on record without amendment where omission was inadvertent...
Proof of foreign public documents requires originals or certified diplomatic/notarial copies; inspection must occur in-magna presence and cross-examin...
Prior Sanction Requirement: absence of prescribed approval invalidates reassessment notice; limitation also bars notice if escaped income below thresh...
Eligibility for exemption depends on strict construction of the product description; reapers without binder are ineligible, but confiscation and penal...
In transfer pricing for sale of goods to associated enterprises, the Tribunal accepted TNMM at entity level and rejected the internal cost plus method because earlier coordinate bench decisions on identical facts had already approved TNMM, and no material factual change was shown; the transfer pricing adjustment was deleted. On reversal of provisions, it held that amounts already disallowed when created cannot be taxed again on reversal, but remitted the issue to the Assessing Officer for verification of the claimed accounting mismatch and reconciliation. For short grant of TDS/TCS credit, it directed factual verification from Form 26AS, AIS and supporting records, with due credit to be allowed in accordance with law.
In transfer pricing for sale of goods to associated enterprises, the Tribunal accepted TNMM at entity level and rejected the internal cost plus method because earlier coordinate bench decisions on identical facts had already approved TNMM, and no material factual change was shown; the transfer pricing adjustment was deleted. On reversal of provisions, it held that amounts already disallowed when created cannot be taxed again on reversal, but remitted the issue to the Assessing Officer for verification of the claimed accounting mismatch and reconciliation. For short grant of TDS/TCS credit, it directed factual verification from Form 26AS, AIS and supporting records, with due credit to be allowed in accordance with law.
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