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...
Redemption of confiscated prohibited foreign currency is discretionary, but the discretion must be exercised judiciously on the facts rather than rejected mechanically because the currency is prohibited. Where no material establishes a previous violation and the imposed penalty has been paid, refusal to permit redemption requires reconsideration. Redemption fine must remain within the statutory ceiling and follow principles governing release of confiscated foreign currency. The refusal of release was set aside, with redemption fine to be determined according to law and the currency released upon payment.
Redemption of confiscated prohibited foreign currency is discretionary, but the discretion must be exercised judiciously on the facts rather than rejected mechanically because the currency is prohibited. Where no material establishes a previous violation and the imposed penalty has been paid, refusal to permit redemption requires reconsideration. Redemption fine must remain within the statutory ceiling and follow principles governing release of confiscated foreign currency. The refusal of release was set aside, with redemption fine to be determined according to law and the currency released upon payment.
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