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 58B seeks to vest with the Principal Commissioner of Customs or Commissioner of Customs the power to cancel a licence granted under section 57 or section 58 or section 58A, if the licensee has contravened any provision of the Act or the rules or regulations made thereunder or breached any of the conditions of the licence.
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 58B seeks to vest with the Principal Commissioner of Customs or Commissioner of Customs the power to cancel a licence granted under section 57 or section 58 or section 58A, if the licensee has contravened any provision of the Act or the rules or regulations made thereunder or breached any of the conditions of the licence.
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