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...
Integrated Drive Generator and Starter Generator were examined for tariff classification, and the Tribunal held that CTH 8501 applied because CTH 8511 is confined to generators used with spark-ignition or compression-ignition internal combustion engines. As the goods were used with gas turbine aircraft engines, the department's reclassification failed and the customs duty, interest and consequential demand were set aside. The Customs Broker penalty also failed because the broker does not determine classification, and no overt act, involvement or connivance was proved; the section 117 penalty was therefore unwarranted.
Integrated Drive Generator and Starter Generator were examined for tariff classification, and the Tribunal held that CTH 8501 applied because CTH 8511 is confined to generators used with spark-ignition or compression-ignition internal combustion engines. As the goods were used with gas turbine aircraft engines, the department's reclassification failed and the customs duty, interest and consequential demand were set aside. The Customs Broker penalty also failed because the broker does not determine classification, and no overt act, involvement or connivance was proved; the section 117 penalty was therefore unwarranted.
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