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...
Rejection of declared FOB value and denial of drawback for readymade garments exported under 63 shipping bills were unsustainable because the proceedings relied exclusively on an investigation into separate March 2017 exports. Export remittances matching the declared FOB value had been received, while departmental costing material did not establish overvaluation. No independent enquiry addressed the 63 shipping bills. Consequently, the demand, FOB-value rejection and penalties were set aside, and the appeal succeeded with consequential relief.
Rejection of declared FOB value and denial of drawback for readymade garments exported under 63 shipping bills were unsustainable because the proceedings relied exclusively on an investigation into separate March 2017 exports. Export remittances matching the declared FOB value had been received, while departmental costing material did not establish overvaluation. No independent enquiry addressed the 63 shipping bills. Consequently, the demand, FOB-value rejection and penalties were set aside, and the appeal succeeded with consequential relief.
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