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...
Officers must not make direct references to DGFT for clarification on Foreign Trade Policy interpretation; such issues must first be examined at Group/Section level, escalated through the Deputy/Assistant Commissioner, and sent through the prescribed channel to the Board only after due scrutiny. Commodity-specific interpretational matters are to be referred only after examination and approval by the concerned NAC, where applicable. Any clarification proposal must include facts, relevant FTP provisions, the field view, specific points for clarification, affected case details, live consignments, and urgency. Consignments should not be held up solely for interpretational issues, and provisional assessment or other lawful facilitative measures should be considered to avoid delay in clearance.
Officers must not make direct references to DGFT for clarification on Foreign Trade Policy interpretation; such issues must first be examined at Group/Section level, escalated through the Deputy/Assistant Commissioner, and sent through the prescribed channel to the Board only after due scrutiny. Commodity-specific interpretational matters are to be referred only after examination and approval by the concerned NAC, where applicable. Any clarification proposal must include facts, relevant FTP provisions, the field view, specific points for clarification, affected case details, live consignments, and urgency. Consignments should not be held up solely for interpretational issues, and provisional assessment or other lawful facilitative measures should be considered to avoid delay in clearance.
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