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...
Foreign Trade Policy 2023 now permits applicants outside the Gems & Jewelry Sector to obtain One Star Export House status based on export performance in any two of the three preceding financial years, subject to the other requirements of paragraph 1.25. The general requirement of export performance across all three preceding financial years remains applicable for grant of status, while the Gems & Jewelry Sector continues to require performance in both preceding financial years. The amendment takes immediate effect.
Foreign Trade Policy 2023 now permits applicants outside the Gems & Jewelry Sector to obtain One Star Export House status based on export performance in any two of the three preceding financial years, subject to the other requirements of paragraph 1.25. The general requirement of export performance across all three preceding financial years remains applicable for grant of status, while the Gems & Jewelry Sector continues to require performance in both preceding financial years. The amendment takes immediate effect.
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