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...
Statutory presumption over seized gold under customs law arose only if the Department first established a reasonable belief at seizure, supported by objective material; suspicion, town-area recovery, purity alone, or a recital of foreign origin were insufficient. The Tribunal also held that investigation statements could not, without the safeguards required by law and independent corroboration, sustain findings of smuggling or document fabrication. Because the Revenue failed to prove smuggled origin or conscious falsity in the supporting records, the confiscation failed and the penalties for dealing with confiscable goods and for false documents were set aside.
Statutory presumption over seized gold under customs law arose only if the Department first established a reasonable belief at seizure, supported by objective material; suspicion, town-area recovery, purity alone, or a recital of foreign origin were insufficient. The Tribunal also held that investigation statements could not, without the safeguards required by law and independent corroboration, sustain findings of smuggling or document fabrication. Because the Revenue failed to prove smuggled origin or conscious falsity in the supporting records, the confiscation failed and the penalties for dealing with confiscable goods and for false documents were set aside.
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