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...
Conditional provisional release of seized imported multifunctional devices was directed on safeguards including payment of the enhanced duty as quantified, furnishing of a bank guarantee, and maintenance of transaction details if the goods were onward sold. The note records that the matter was treated on the same footing as an earlier seizure case, and that interim release would not affect the statutory customs adjudication. The adjudicating authority was required to decide the dispute independently, after hearing the importer and without being influenced by the release order.
Conditional provisional release of seized imported multifunctional devices was directed on safeguards including payment of the enhanced duty as quantified, furnishing of a bank guarantee, and maintenance of transaction details if the goods were onward sold. The note records that the matter was treated on the same footing as an earlier seizure case, and that interim release would not affect the statutory customs adjudication. The adjudicating authority was required to decide the dispute independently, after hearing the importer and without being influenced by the release order.
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