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...
A defect in the pre-shipment inspection certificate, caused only by the inspecting agency lacking territorial authorisation for Guyana, did not make the imported metallic scrap prohibited goods. The Tribunal noted that the inspection was in fact carried out by a DGFT-empanelled agency and that a later approved post-shipment inspection confirmed the consignment contained no war material or other objectionable material. On that basis, the import-policy requirement was treated as substantially complied with, the lapse at most justified examination of the goods, and confiscation under Section 111(d), along with redemption fine and penalties, was unsustainable.
A defect in the pre-shipment inspection certificate, caused only by the inspecting agency lacking territorial authorisation for Guyana, did not make the imported metallic scrap prohibited goods. The Tribunal noted that the inspection was in fact carried out by a DGFT-empanelled agency and that a later approved post-shipment inspection confirmed the consignment contained no war material or other objectionable material. On that basis, the import-policy requirement was treated as substantially complied with, the lapse at most justified examination of the goods, and confiscation under Section 111(d), along with redemption fine and penalties, was unsustainable.
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