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...
Imported electric ride-on toy components comprising only 60-65% of the parts needed for a complete toy, with essential components absent, are treated as toy parts rather than complete toys in CKD/SKD condition. Assembly with locally procured or manufactured components and subsequent testing produces a distinct finished product and constitutes manufacture under the concessional-duty import rules. Such imports are classified under CTH 95030091 and qualify for concessional customs-duty exemption under Notification No. 50/2017-Cus. The Toys (Quality Control) Order, 2020 does not apply because toy parts cannot independently be regarded as toys and BIS certification is not required for them.
Imported electric ride-on toy components comprising only 60-65% of the parts needed for a complete toy, with essential components absent, are treated as toy parts rather than complete toys in CKD/SKD condition. Assembly with locally procured or manufactured components and subsequent testing produces a distinct finished product and constitutes manufacture under the concessional-duty import rules. Such imports are classified under CTH 95030091 and qualify for concessional customs-duty exemption under Notification No. 50/2017-Cus. The Toys (Quality Control) Order, 2020 does not apply because toy parts cannot independently be regarded as toys and BIS certification is not required for them.
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