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...
Customs duty cannot be fastened jointly and severally on multiple noticees without first determining the actual importer and the role of each person. The Tribunal held that the adjudicating authority must examine the documentary evidence, record clear factual findings on individual responsibility, and then fix duty and penalty, if warranted, on the person concerned. Because the impugned order had imposed liability without that determination, it was set aside against the appellants and the matter was remanded for de novo adjudication by a speaking order, with all contentions left open.
Customs duty cannot be fastened jointly and severally on multiple noticees without first determining the actual importer and the role of each person. The Tribunal held that the adjudicating authority must examine the documentary evidence, record clear factual findings on individual responsibility, and then fix duty and penalty, if warranted, on the person concerned. Because the impugned order had imposed liability without that determination, it was set aside against the appellants and the matter was remanded for de novo adjudication by a speaking order, with all contentions left open.
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