Pure-agent exclusion fails where hotel booking facilitators receive third-party services themselves, making entire customer consideration taxable as r...
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...
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Duty demand - Manufacture of transmission assembly - Captive consumption - during the period 1996-1998, the tractors with capacity of less than 1800 cc were exempt - demand set aside on the ground of period of limitation as it is not sustainable to allege suppression of facts or wilful mis-statement on the part of the appellants - AT
Duty demand - Manufacture of transmission assembly - Captive consumption - during the period 1996-1998, the tractors with capacity of less than 1800 cc were exempt - demand set aside on the ground of period of limitation as it is not sustainable to allege suppression of facts or wilful mis-statement on the part of the appellants - AT
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