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...
Rebate of duty - Rule 18 of the CE Rules, 2002 - Authority rejected revision application on ground of delay stating that same cannot be accepted as a general rule on the basis of relying upon decision - the official could not have summarily distinguished a binding judgment of the Supreme Court - the impugned order has resulted in the lack of remedy which is otherwise statutory guaranteed - quashed and remanded
Rebate of duty - Rule 18 of the CE Rules, 2002 - Authority rejected revision application on ground of delay stating that same cannot be accepted as a general rule on the basis of relying upon decision - the official could not have summarily distinguished a binding judgment of the Supreme Court - the impugned order has resulted in the lack of remedy which is otherwise statutory guaranteed - quashed and remanded
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