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...
Classification of a fortified soy protein product turned on the tariff terms, Chapter Notes and the General Rules for Interpretation rather than food-standard labels. Although Heading 3504 covers protein isolates, the product's 82% protein content, added calcium phosphate and fortified imported form showed it was not a plain soy protein isolate but a formulated nutritional preparation. The reliance on Codex and FSSAI standards was non-determinative for customs classification. Applying the HSN Notes to Heading 2106 and Chapter Note 5 to Chapter 21, the product was treated as a protein-based food preparation for enrichment of foods and beverages, and tariff item 21061000 was preferred over Heading 3504.
Classification of a fortified soy protein product turned on the tariff terms, Chapter Notes and the General Rules for Interpretation rather than food-standard labels. Although Heading 3504 covers protein isolates, the product's 82% protein content, added calcium phosphate and fortified imported form showed it was not a plain soy protein isolate but a formulated nutritional preparation. The reliance on Codex and FSSAI standards was non-determinative for customs classification. Applying the HSN Notes to Heading 2106 and Chapter Note 5 to Chapter 21, the product was treated as a protein-based food preparation for enrichment of foods and beverages, and tariff item 21061000 was preferred over Heading 3504.
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