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...
Parity with an accepted co-ordinate Tribunal order supported setting aside revocation of a Customs Broker licence. The Tribunal had found that alleged contraventions of the Customs Broker Licensing Regulations, 2018 were not established in an analogous matter involving the same exporter. As the Revenue identified no material factual distinction and had accepted the earlier Tribunal decision without challenge, no substantial question of law arose. The High Court therefore upheld the setting aside of the licence revocation and dismissed the Revenue's appeal.
Parity with an accepted co-ordinate Tribunal order supported setting aside revocation of a Customs Broker licence. The Tribunal had found that alleged contraventions of the Customs Broker Licensing Regulations, 2018 were not established in an analogous matter involving the same exporter. As the Revenue identified no material factual distinction and had accepted the earlier Tribunal decision without challenge, no substantial question of law arose. The High Court therefore upheld the setting aside of the licence revocation and dismissed the Revenue's appeal.
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