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...
Imported embroidery threads were re-valued on the basis of the full transaction value because supplementary invoices and admitted extra payments showed that part of the price had been kept outside the banking channel. The absence of comparable import data did not defeat the demand, since the undervaluation was supported by the appellants' own documents and admissions. The Tribunal sustained the differential customs duty after re-determining the assessable value under the valuation rules, and upheld penalties on both the importer and its Director because the same evidence established suppression and wilful misstatement.
Imported embroidery threads were re-valued on the basis of the full transaction value because supplementary invoices and admitted extra payments showed that part of the price had been kept outside the banking channel. The absence of comparable import data did not defeat the demand, since the undervaluation was supported by the appellants' own documents and admissions. The Tribunal sustained the differential customs duty after re-determining the assessable value under the valuation rules, and upheld penalties on both the importer and its Director because the same evidence established suppression and wilful misstatement.
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