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...
Excisability/marketability - Captive consumption - cream - Department has not been able to bring any evidence of marketability of creams so manufactured by the appellant - the cream captively produced and consumed in the factory is not marketable as there is no evidence to that effect
Excisability/marketability - Captive consumption - cream - Department has not been able to bring any evidence of marketability of creams so manufactured by the appellant - the cream captively produced and consumed in the factory is not marketable as there is no evidence to that effect
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