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...
Complete knee, hip and shoulder replacement systems were classified as artificial joints, while separately imported stem and acetabular components were classified as other artificial parts of the body. The claim that they were orthopaedic appliances failed because Heading 9021 and the HSN distinguish support devices from replacement prostheses. Exemption under Sr. No. 385 of Notification No. 45/2025-Cus was denied: Entry B(1) applies only to orthopaedic appliances, and Entry E(9) requires implants for severely physically handicapped patients. The applicant did not show that these general-use implants met that narrower description, so strict construction of the exemption defeated the claim.
Complete knee, hip and shoulder replacement systems were classified as artificial joints, while separately imported stem and acetabular components were classified as other artificial parts of the body. The claim that they were orthopaedic appliances failed because Heading 9021 and the HSN distinguish support devices from replacement prostheses. Exemption under Sr. No. 385 of Notification No. 45/2025-Cus was denied: Entry B(1) applies only to orthopaedic appliances, and Entry E(9) requires implants for severely physically handicapped patients. The applicant did not show that these general-use implants met that narrower description, so strict construction of the exemption defeated the claim.
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