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...
Immediate suspension of a Customs Cargo Service Provider approval under HCCAR is an exceptional measure and can be used only where an inquiry is pending or contemplated; absent a show-cause notice or other substantiated basis for such inquiry, continuation of suspension is unsustainable. The Tribunal also held that an indefinite prohibition on fresh receipt of import or export cargo was inconsistent with HCCAR, which contemplates only temporary regulation of cargo entry, while preserving the authority's power to proceed under Regulation 12 after inquiry. On the material placed, allegations of smuggling, unauthorized removal, and security lapses required regular inquiry and factual substantiation, so the continued suspension order was set aside with liberty to initiate proceedings under the prescribed procedure.
Immediate suspension of a Customs Cargo Service Provider approval under HCCAR is an exceptional measure and can be used only where an inquiry is pending or contemplated; absent a show-cause notice or other substantiated basis for such inquiry, continuation of suspension is unsustainable. The Tribunal also held that an indefinite prohibition on fresh receipt of import or export cargo was inconsistent with HCCAR, which contemplates only temporary regulation of cargo entry, while preserving the authority's power to proceed under Regulation 12 after inquiry. On the material placed, allegations of smuggling, unauthorized removal, and security lapses required regular inquiry and factual substantiation, so the continued suspension order was set aside with liberty to initiate proceedings under the prescribed procedure.
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