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...
Melting and converting imported bullion into bars, coins, medals and gift items on job-work basis was treated as manufacture because the process produced goods with a distinct character and use. Extended limitation and penalty were rejected because the dispute turned on classification and interpretation, transactions were accounted for, and no intent to evade duty was shown. Gold bars and imported bullion were classified as primary gold under Heading 7108 and held exempt, and branded gold and silver coins made from duty-paid metal were also exempt; medals, medallions and gift items remained dutiable at 1% for the normal period only, while Rule 12AA was held inapplicable.
Melting and converting imported bullion into bars, coins, medals and gift items on job-work basis was treated as manufacture because the process produced goods with a distinct character and use. Extended limitation and penalty were rejected because the dispute turned on classification and interpretation, transactions were accounted for, and no intent to evade duty was shown. Gold bars and imported bullion were classified as primary gold under Heading 7108 and held exempt, and branded gold and silver coins made from duty-paid metal were also exempt; medals, medallions and gift items remained dutiable at 1% for the normal period only, while Rule 12AA was held inapplicable.
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