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...
Post-export conversion of shipping bills from the Advance Authorisation Scheme to the duty drawback scheme cannot be refused solely because a request exceeds the three-month period prescribed by Circular No. 36/2010-Cus. That circular-based limitation is inconsistent with the statutory framework governing amendment of customs documents, and consequential export benefits remain available after export. Notification No. 11/2022-Cus. (N.T.), which introduced time limits for specified post-export conversions, does not apply retrospectively to exports made before its introduction. Shipping bills for such earlier exports remain eligible for conversion without denial based on either the circular limitation or the later notification.
Post-export conversion of shipping bills from the Advance Authorisation Scheme to the duty drawback scheme cannot be refused solely because a request exceeds the three-month period prescribed by Circular No. 36/2010-Cus. That circular-based limitation is inconsistent with the statutory framework governing amendment of customs documents, and consequential export benefits remain available after export. Notification No. 11/2022-Cus. (N.T.), which introduced time limits for specified post-export conversions, does not apply retrospectively to exports made before its introduction. Shipping bills for such earlier exports remain eligible for conversion without denial based on either the circular limitation or the later notification.
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