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...
Calcined kaolin clay remained classifiable under Chapter 25 because Heading 2507 expressly covers kaolin and other kaolinic clays, whether or not calcined. The Tribunal found that the product information and chemical test report showed only calcined clay mainly composed of aluminium silicate with trace elements, which did not change its character for classification. It further held that the goods were not shown to be separate chemically defined compounds attracting Chapter 28. The reclassification under CTI 2839 9090 was rejected and CTI 2507 0029 was accepted.
Calcined kaolin clay remained classifiable under Chapter 25 because Heading 2507 expressly covers kaolin and other kaolinic clays, whether or not calcined. The Tribunal found that the product information and chemical test report showed only calcined clay mainly composed of aluminium silicate with trace elements, which did not change its character for classification. It further held that the goods were not shown to be separate chemically defined compounds attracting Chapter 28. The reclassification under CTI 2839 9090 was rejected and CTI 2507 0029 was accepted.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4801
Join Channel
TaxTMI 
