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...
Burden of proof for reclassification rests on Revenue where imported lead-bearing powder is proposed to be classified as lead waste and scrap rather than declared lead concentrate. Conflicting scientific reports that identify principally lead oxide and lead sulphate, with only negligible metallic lead, do not conclusively establish classification under tariff item 78020090. Heading 7802 concerns lead in metallic or primary form, while lead oxide and lead sulphate fall separately within Chapter 28. Technical literature and import-export descriptions cannot displace the declared classification without reliable scientific proof of the goods' identity.
Burden of proof for reclassification rests on Revenue where imported lead-bearing powder is proposed to be classified as lead waste and scrap rather than declared lead concentrate. Conflicting scientific reports that identify principally lead oxide and lead sulphate, with only negligible metallic lead, do not conclusively establish classification under tariff item 78020090. Heading 7802 concerns lead in metallic or primary form, while lead oxide and lead sulphate fall separately within Chapter 28. Technical literature and import-export descriptions cannot displace the declared classification without reliable scientific proof of the goods' identity.
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