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...
Fire-damaged motor cars brought with a vessel for ship-breaking may be classified as scrap where extensive damage has destroyed their identity and utility as motor vehicles, and salvage arrangements restrict disposal to demolition. Such goods are not restricted commercial or passenger vehicles, usable second-hand goods, or prohibited imports; confiscation for import without a licence is therefore not attracted. Unloading requires physical removal of cargo from a vessel; berthing at a notified ship-breaking port is not unloading. Where no unauthorised removal or other statutory contravention is established, neither the scrap cargo nor the vessel carrying it is liable to confiscation, and consequential penalties are unsustainable.
Fire-damaged motor cars brought with a vessel for ship-breaking may be classified as scrap where extensive damage has destroyed their identity and utility as motor vehicles, and salvage arrangements restrict disposal to demolition. Such goods are not restricted commercial or passenger vehicles, usable second-hand goods, or prohibited imports; confiscation for import without a licence is therefore not attracted. Unloading requires physical removal of cargo from a vessel; berthing at a notified ship-breaking port is not unloading. Where no unauthorised removal or other statutory contravention is established, neither the scrap cargo nor the vessel carrying it is liable to confiscation, and consequential penalties are unsustainable.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4800
Join Channel
TaxTMI 
