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...
For export consignments, test reports from NABL-accredited laboratories, EPC-recognised laboratories or other recognised agencies may be accepted for compliance with the destination country's regulatory requirements, and the proper officer need not mandatorily send such samples to CRCL where there is no risk-based intervention or intelligence. Where risk-based intervention or intelligence exists, the existing procedure for withdrawal and testing of samples, including referral to CRCL or other accredited laboratories, continues to apply. The procedure for import consignments is unchanged and import samples remain subject to existing drawal and testing instructions.
For export consignments, test reports from NABL-accredited laboratories, EPC-recognised laboratories or other recognised agencies may be accepted for compliance with the destination country's regulatory requirements, and the proper officer need not mandatorily send such samples to CRCL where there is no risk-based intervention or intelligence. Where risk-based intervention or intelligence exists, the existing procedure for withdrawal and testing of samples, including referral to CRCL or other accredited laboratories, continues to apply. The procedure for import consignments is unchanged and import samples remain subject to existing drawal and testing instructions.
Note: It is a system-generated summary and is for quick reference only.
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