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...
Transferee importers using duty-free DFIA licences linked to fabricated exports must independently verify licence authenticity, underlying export documents and transfer release advice. Verification solely through the DGFT website is insufficient. Purchase through intermediaries does not remove customs duty, interest or penalty exposure where the importer fails to undertake due diligence with licensing or Customs authorities regarding the issuing exporter and claimed exports. The stated Tribunal approach treats absence of such verification as sufficient to sustain liability for imports made under fraudulent transferable export incentive licences.
Transferee importers using duty-free DFIA licences linked to fabricated exports must independently verify licence authenticity, underlying export documents and transfer release advice. Verification solely through the DGFT website is insufficient. Purchase through intermediaries does not remove customs duty, interest or penalty exposure where the importer fails to undertake due diligence with licensing or Customs authorities regarding the issuing exporter and claimed exports. The stated Tribunal approach treats absence of such verification as sufficient to sustain liability for imports made under fraudulent transferable export incentive licences.
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