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...
Customs show cause notice adjudication must ordinarily be completed within one year under the unamended framework, unless the officer demonstrates that completion was impracticable. The phrase "where it is possible to do so" does not allow proceedings to remain pending indefinitely or for an unreasonable period. Limitation affects jurisdiction, rendering an order passed beyond the applicable period invalid. Although a procedural amendment may generally operate retrospectively, it cannot revive a stale claim; adjudication must also satisfy any extended period available under the amended regime. Unsupported placement in the Call Book does not justify prolonged delay. Unreasonable and arbitrary delay in adjudication violates Article 14 and can invalidate the resulting customs order.
Customs show cause notice adjudication must ordinarily be completed within one year under the unamended framework, unless the officer demonstrates that completion was impracticable. The phrase "where it is possible to do so" does not allow proceedings to remain pending indefinitely or for an unreasonable period. Limitation affects jurisdiction, rendering an order passed beyond the applicable period invalid. Although a procedural amendment may generally operate retrospectively, it cannot revive a stale claim; adjudication must also satisfy any extended period available under the amended regime. Unsupported placement in the Call Book does not justify prolonged delay. Unreasonable and arbitrary delay in adjudication violates Article 14 and can invalidate the resulting customs order.
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