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...
Related-party customs valuation requires objectively founded reasonable doubt before rejecting the declared transaction value. Non-disclosure of an exporter's Suggested List Price, without evidence that the discount was abnormal, artificial or relationship-driven, does not justify rejection where comparable export-country discounts and commercial normality are established. Any reassessment must follow the prescribed valuation methods sequentially; the residual method cannot use the exporter's domestic-market price. Royalty, technical assistance and know-how fees are includible only when they relate to imported goods and are payable as a condition of sale. Payments for Indian manufacturing technology, and discontinued notional management fees, are therefore excluded absent evidence of import-price adjustment.
Related-party customs valuation requires objectively founded reasonable doubt before rejecting the declared transaction value. Non-disclosure of an exporter's Suggested List Price, without evidence that the discount was abnormal, artificial or relationship-driven, does not justify rejection where comparable export-country discounts and commercial normality are established. Any reassessment must follow the prescribed valuation methods sequentially; the residual method cannot use the exporter's domestic-market price. Royalty, technical assistance and know-how fees are includible only when they relate to imported goods and are payable as a condition of sale. Payments for Indian manufacturing technology, and discontinued notional management fees, are therefore excluded absent evidence of import-price adjustment.
Note: It is a system-generated summary and is for quick reference only.
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