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...
Section 110 distinguishes goods seized for confiscation from documents or things retained as useful or relevant to Customs Act proceedings. The six-month notice period applies to goods seized under Section 110(1), but not to currency treated as a "thing" under Section 110(3) when retained as evidence in an investigation into fraudulent amnesty claims, suspected hawala transactions, illegal gratification, or related offences. Currency is treated as goods where it is itself the subject of a customs violation, such as undeclared cross-border carriage. The return direction was set aside, and the currency was to be deposited in an interest-bearing nationalised-bank scheme pending investigation.
Section 110 distinguishes goods seized for confiscation from documents or things retained as useful or relevant to Customs Act proceedings. The six-month notice period applies to goods seized under Section 110(1), but not to currency treated as a "thing" under Section 110(3) when retained as evidence in an investigation into fraudulent amnesty claims, suspected hawala transactions, illegal gratification, or related offences. Currency is treated as goods where it is itself the subject of a customs violation, such as undeclared cross-border carriage. The return direction was set aside, and the currency was to be deposited in an interest-bearing nationalised-bank scheme pending investigation.
Note: It is a system-generated summary and is for quick reference only.