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...
Classification of aluminium hollow profiles depends on their objective characteristics, nature and physical attributes when presented for assessment, rather than commercial description or intended downstream use unless the tariff makes end use relevant. Uniform cross-section profiles cut to shorter lengths remain profiles and fall under CTI 76042100, not the residuary heading for other aluminium articles, absent evidence that they constitute complete frames or finished articles. The concessional customs exemption for Solar PV Module manufacture applies where the prescribed import procedure and valid end-use certificates are satisfied; it cannot be denied based on hypothetical alternative uses. The exemption remains available for qualifying bills of entry filed before the amendment took effect.
Classification of aluminium hollow profiles depends on their objective characteristics, nature and physical attributes when presented for assessment, rather than commercial description or intended downstream use unless the tariff makes end use relevant. Uniform cross-section profiles cut to shorter lengths remain profiles and fall under CTI 76042100, not the residuary heading for other aluminium articles, absent evidence that they constitute complete frames or finished articles. The concessional customs exemption for Solar PV Module manufacture applies where the prescribed import procedure and valid end-use certificates are satisfied; it cannot be denied based on hypothetical alternative uses. The exemption remains available for qualifying bills of entry filed before the amendment took effect.
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