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...
Provisional release of seized imported multifunctional devices was directed on specified conditions, with the court treating the matter as one for interim release pending adjudication and following the same approach adopted in similar matters. Release was made subject to payment of the quantified enhanced duty, furnishing of a bank guarantee for the prescribed percentage of the goods' value, and maintenance of transaction details if the goods were provisionally sold. The order also preserved the adjudicating authority's power to decide the proceedings independently on their own merits after hearing the petitioner.
Provisional release of seized imported multifunctional devices was directed on specified conditions, with the court treating the matter as one for interim release pending adjudication and following the same approach adopted in similar matters. Release was made subject to payment of the quantified enhanced duty, furnishing of a bank guarantee for the prescribed percentage of the goods' value, and maintenance of transaction details if the goods were provisionally sold. The order also preserved the adjudicating authority's power to decide the proceedings independently on their own merits after hearing the petitioner.
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