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...
Substitution of new sections 58, 58A and 58B for section 58 of Customs Act, 1962 - Licensing of private warehouses- Licensing of special warehouses - Cancellation of Licence - The proposed section 58A seeks to vest with the Principal Commissioner of Customs or Commissioner of Customs the power to license a special warehouse wherein dutiable goods may be deposited and such warehouse shall be caused to be locked by the proper officer and no person shall enter the warehouse or remove any goods therefrom without the permission of proper officer.
Substitution of new sections 58, 58A and 58B for section 58 of Customs Act, 1962 - Licensing of private warehouses- Licensing of special warehouses - Cancellation of Licence - The proposed section 58A seeks to vest with the Principal Commissioner of Customs or Commissioner of Customs the power to license a special warehouse wherein dutiable goods may be deposited and such warehouse shall be caused to be locked by the proper officer and no person shall enter the warehouse or remove any goods therefrom without the permission of proper officer.
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