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 detention of imported goods is synonymous with seizure once the goods are under Customs control and cannot be cleared without permission; a formal seizure memo is only a later procedural step. The six-month period for issuing a show-cause notice therefore runs from initial detention. Any statutory extension of that period must be granted and communicated before the original period expires; a later extension is without jurisdiction. The time-barred extension was quashed and the goods were directed to be released upon an indemnity bond and proof that any sale would be solely for animal-feed use. Classification, duty liability and the goods' nature remain open for adjudication.
Customs detention of imported goods is synonymous with seizure once the goods are under Customs control and cannot be cleared without permission; a formal seizure memo is only a later procedural step. The six-month period for issuing a show-cause notice therefore runs from initial detention. Any statutory extension of that period must be granted and communicated before the original period expires; a later extension is without jurisdiction. The time-barred extension was quashed and the goods were directed to be released upon an indemnity bond and proof that any sale would be solely for animal-feed use. Classification, duty liability and the goods' nature remain open for adjudication.
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