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...
DIGIT data entry has been revised to ensure uniform classification, mandatory capture, and timely updating of offence cases. Only specified offence cases are to be entered, namely outright smuggling, commercial fraud, and NDPS/Wildlife and allied Act cases, with classification governed by the principal statute booked; minor cases below prescribed value thresholds and audit detections need not be entered, though reward eligibility still requires entry. Entry is required at defined stages such as search, summons, seizure, arrest, investigation, adjudication, post-adjudication, and prosecution, with strict timelines generally running from 5 days or by the 5th day of the following month. The instruction also prescribes detailed user data capture, nodal officer administration, and reconciliation of DIGIT with MPR.
DIGIT data entry has been revised to ensure uniform classification, mandatory capture, and timely updating of offence cases. Only specified offence cases are to be entered, namely outright smuggling, commercial fraud, and NDPS/Wildlife and allied Act cases, with classification governed by the principal statute booked; minor cases below prescribed value thresholds and audit detections need not be entered, though reward eligibility still requires entry. Entry is required at defined stages such as search, summons, seizure, arrest, investigation, adjudication, post-adjudication, and prosecution, with strict timelines generally running from 5 days or by the 5th day of the following month. The instruction also prescribes detailed user data capture, nodal officer administration, and reconciliation of DIGIT with MPR.
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