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...
Penalty on appellant-CHA - abetting in the mis-declaration of the imported goods - the case cannot be built on the basis of vague statement of the co-accused and mere existence of call records - neither any evidence has been found during the search of the Appellant residence nor it is clear whether investigation could reach of the actual importer - penalty without properly establishing his role is not acceptable
Penalty on appellant-CHA - abetting in the mis-declaration of the imported goods - the case cannot be built on the basis of vague statement of the co-accused and mere existence of call records - neither any evidence has been found during the search of the Appellant residence nor it is clear whether investigation could reach of the actual importer - penalty without properly establishing his role is not acceptable
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