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...
Advance ruling was barred for roasted areca nuts because their classification had already been upheld by the High Court and no new facts were presented; the application was therefore disallowed without a merits ruling. Roasted walnuts subjected to severe heat treatment were distinguished from dried nuts, as roasting materially changes moisture, colour, appearance and flavour. Because Chapter 8 does not contemplate roasting, the walnuts fall under Heading 2008 and are classified as other roasted nuts and seeds under CTI 2008 19 91. Preferential customs duty is available only where the importer proves origin to the competent customs officer under the applicable origin rules and the Customs (Administration of Rules of Origin under Trade Agreements) Rules, 2020.
Advance ruling was barred for roasted areca nuts because their classification had already been upheld by the High Court and no new facts were presented; the application was therefore disallowed without a merits ruling. Roasted walnuts subjected to severe heat treatment were distinguished from dried nuts, as roasting materially changes moisture, colour, appearance and flavour. Because Chapter 8 does not contemplate roasting, the walnuts fall under Heading 2008 and are classified as other roasted nuts and seeds under CTI 2008 19 91. Preferential customs duty is available only where the importer proves origin to the competent customs officer under the applicable origin rules and the Customs (Administration of Rules of Origin under Trade Agreements) Rules, 2020.
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