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...
Technical expert opinion in customs classification and exemption disputes must be meaningfully evaluated where eligibility depends on physical inspection and component-level analysis. An adjudicating authority cannot reject such opinion through its own technical perception without a reasoned technical rebuttal supported by comparable expert or scientific material. The order denying concessional customs duty for Battery Management Systems and Cell Supervisory Circuits was quashed and remanded for fresh adjudication, with liberty to obtain a counter-expert opinion. Writ jurisdiction was exercised despite an alternative appellate remedy because the specialised technical opinion had been disregarded without a reasoned technical basis.
Technical expert opinion in customs classification and exemption disputes must be meaningfully evaluated where eligibility depends on physical inspection and component-level analysis. An adjudicating authority cannot reject such opinion through its own technical perception without a reasoned technical rebuttal supported by comparable expert or scientific material. The order denying concessional customs duty for Battery Management Systems and Cell Supervisory Circuits was quashed and remanded for fresh adjudication, with liberty to obtain a counter-expert opinion. Writ jurisdiction was exercised despite an alternative appellate remedy because the specialised technical opinion had been disregarded without a reasoned technical basis.
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