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...
Indoor and outdoor units of a VRF air-conditioning system were treated as parts of air conditioners, not complete split system air conditioners, because the imported goods lacked other essential components needed for installation and operation. Purchase orders showed VRF-based models, and the tribunal held that omission of VRF reference in the invoice or import under a single invoice did not change the character of the goods. Following prior precedent, the goods were classified under CTH 8415 9000, and the denial of notification benefit based on a different classification was not sustained.
Indoor and outdoor units of a VRF air-conditioning system were treated as parts of air conditioners, not complete split system air conditioners, because the imported goods lacked other essential components needed for installation and operation. Purchase orders showed VRF-based models, and the tribunal held that omission of VRF reference in the invoice or import under a single invoice did not change the character of the goods. Following prior precedent, the goods were classified under CTH 8415 9000, and the denial of notification benefit based on a different classification was not sustained.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4801
Join Channel
TaxTMI 
