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...
FTWZ operations were not treated as having been undertaken under the customs broker licence because there was no Form C intimation extending the licence to SEZ/FTWZ activity and no evidence that the licence covered business in the SEZ unit. The inquiry report was treated as the ative document in the CBLR proceedings; once it recorded that the alleged violations of Regulation 10(d), (e) and (n) were not proved, revocation of licence, forfeiture of security and penalty could not be sustained. The order dropping the proceedings was upheld and the Revenue appeal was dismissed.
FTWZ operations were not treated as having been undertaken under the customs broker licence because there was no Form C intimation extending the licence to SEZ/FTWZ activity and no evidence that the licence covered business in the SEZ unit. The inquiry report was treated as the ative document in the CBLR proceedings; once it recorded that the alleged violations of Regulation 10(d), (e) and (n) were not proved, revocation of licence, forfeiture of security and penalty could not be sustained. The order dropping the proceedings was upheld and the Revenue appeal was dismissed.
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