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...
EPCG duty exemption requires strict compliance with the stipulated export obligation. Failure to meet that obligation makes the duty saved and applicable interest recoverable unless a waiver is obtained from the competent EPCG or DGFT authority; flood damage to imported machinery did not establish such waiver. The machinery had been installed but was subsequently submerged and damaged beyond repair. While duty and interest liability for non-fulfilment of export obligation remained enforceable, confiscation, redemption fine and penalties were not sustained in those circumstances. The exemption condition was applied strictly, with the importer bearing the burden of proving entitlement to the exemption.
EPCG duty exemption requires strict compliance with the stipulated export obligation. Failure to meet that obligation makes the duty saved and applicable interest recoverable unless a waiver is obtained from the competent EPCG or DGFT authority; flood damage to imported machinery did not establish such waiver. The machinery had been installed but was subsequently submerged and damaged beyond repair. While duty and interest liability for non-fulfilment of export obligation remained enforceable, confiscation, redemption fine and penalties were not sustained in those circumstances. The exemption condition was applied strictly, with the importer bearing the burden of proving entitlement to the exemption.
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