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...
Social Welfare Surcharge on imports under MEIS/SEIS duty-credit scrips depends on customs duties levied and collected, rather than notional duty quantified or debited under an exemption mechanism. Where notifications exempt goods from basic customs duty and the equivalent amount is debited in scrips, the debit does not constitute actual duty realisation. The surcharge base is therefore nil, making a separate surcharge exemption unnecessary. The Board circular is characterised as clarificatory and applicable to pending earlier-period disputes, while warehousing and education-cess rulings are distinguishable.
Social Welfare Surcharge on imports under MEIS/SEIS duty-credit scrips depends on customs duties levied and collected, rather than notional duty quantified or debited under an exemption mechanism. Where notifications exempt goods from basic customs duty and the equivalent amount is debited in scrips, the debit does not constitute actual duty realisation. The surcharge base is therefore nil, making a separate surcharge exemption unnecessary. The Board circular is characterised as clarificatory and applicable to pending earlier-period disputes, while warehousing and education-cess rulings are distinguishable.
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