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...
Verifiable evidence of lawful domestic procurement can discharge the claimant's burden for notified gold. Supplier invoices, bank-payment records and GST returns require departmental verification and rebuttal; foreign markings, delayed production of documents and uncorroborated or retracted statements do not by themselves establish smuggling or justify final confiscation. Initial seizure may rest on credible intelligence and reasonable belief, but final confiscation requires proof. Indian currency may be confiscated as smuggled-goods sale proceeds only upon proof of a proximate, identifiable link to specified smuggled goods and knowing dealings. Where these requirements are unmet, confiscation and related penalties are unsustainable.
Verifiable evidence of lawful domestic procurement can discharge the claimant's burden for notified gold. Supplier invoices, bank-payment records and GST returns require departmental verification and rebuttal; foreign markings, delayed production of documents and uncorroborated or retracted statements do not by themselves establish smuggling or justify final confiscation. Initial seizure may rest on credible intelligence and reasonable belief, but final confiscation requires proof. Indian currency may be confiscated as smuggled-goods sale proceeds only upon proof of a proximate, identifiable link to specified smuggled goods and knowing dealings. Where these requirements are unmet, confiscation and related penalties are unsustainable.
Note: It is a system-generated summary and is for quick reference only.
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