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...
Imported nickel-chromium wire could not be reclassified where the dispute was already covered by the co-ordinate Bench decision in the appellant's own case. The Tribunal noted that the earlier ruling had examined the same goods with reference to the mill test certificate, chapter notes and sub-heading notes, and had rejected the Department's classification. As no factual distinction or change in law was shown, the reclassification was unsustainable. The impugned order was set aside, the appeal was allowed, and consequential benefits followed as per law.
Imported nickel-chromium wire could not be reclassified where the dispute was already covered by the co-ordinate Bench decision in the appellant's own case. The Tribunal noted that the earlier ruling had examined the same goods with reference to the mill test certificate, chapter notes and sub-heading notes, and had rejected the Department's classification. As no factual distinction or change in law was shown, the reclassification was unsustainable. The impugned order was set aside, the appeal was allowed, and consequential benefits followed as per law.
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