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...
Valuation - enhancement of value - revenue neutrality - if duty had been paid by the appellants at the time of clearances, the same would have been available as cenvat credit in the hands of the buyer. Even of the appellants pay the differential duty, the same will be available as credit to the buyer. On this count also the issue is revenue neutral. - AT
Valuation - enhancement of value - revenue neutrality - if duty had been paid by the appellants at the time of clearances, the same would have been available as cenvat credit in the hands of the buyer. Even of the appellants pay the differential duty, the same will be available as credit to the buyer. On this count also the issue is revenue neutral. - AT
Note: It is a system-generated summary and is for quick reference only.