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...
Writ jurisdiction does not ordinarily permit resolution of disputed facts concerning the presence of a Customs Broker during sampling of seized imported industrial oil. The objection to the first sample depended on a factual dispute: the importer denied the representative's presence, while the respondents and sampling report recorded it. The representative's presence during subsequent sampling was admitted. The relevant test report also indicated that the declared industrial oil failed applicable parameters, an issue addressed in an earlier decision. The challenge to seizure was therefore rejected, with no interference warranted on the disputed sampling objection.
Writ jurisdiction does not ordinarily permit resolution of disputed facts concerning the presence of a Customs Broker during sampling of seized imported industrial oil. The objection to the first sample depended on a factual dispute: the importer denied the representative's presence, while the respondents and sampling report recorded it. The representative's presence during subsequent sampling was admitted. The relevant test report also indicated that the declared industrial oil failed applicable parameters, an issue addressed in an earlier decision. The challenge to seizure was therefore rejected, with no interference warranted on the disputed sampling objection.
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