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...
By-products emerging from crude oil refining were treated as "resultant goods" under the MOOWR framework because the expression is to be understood in its ordinary and commercial sense, covering all goods produced in the manufacturing process and not only the principal output. The advance ruling also accepted that export of such resultant goods permits proportionate remission of duty on the imported crude oils attributable to the exported output, with correlation to be shown through proper accounting, yield ratios and material balance. Goods cleared for home consumption remain liable only to the corresponding attributable duty. The application was held maintainable as it concerned duty liability and remission under the warehousing scheme.
By-products emerging from crude oil refining were treated as "resultant goods" under the MOOWR framework because the expression is to be understood in its ordinary and commercial sense, covering all goods produced in the manufacturing process and not only the principal output. The advance ruling also accepted that export of such resultant goods permits proportionate remission of duty on the imported crude oils attributable to the exported output, with correlation to be shown through proper accounting, yield ratios and material balance. Goods cleared for home consumption remain liable only to the corresponding attributable duty. The application was held maintainable as it concerned duty liability and remission under the warehousing scheme.
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