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...
Classification of services - Synthetic Filament Yarn - The moment the yarn is of multifilament nature, it goes out of Heading 5402. Therefore, as far as the tariff entries till 2004-05 are concerned, the assessee’s contention of classification under 5404.90 cannot be accepted. From 2005-06 also, the heading remains of synthetic monofilament yarn of 67 decitex or more. Therefore, from 2005-06 the Heading is not applicable to the appellants on the basis of the Chemical Examiners report.
Classification of services - Synthetic Filament Yarn - The moment the yarn is of multifilament nature, it goes out of Heading 5402. Therefore, as far as the tariff entries till 2004-05 are concerned, the assessee’s contention of classification under 5404.90 cannot be accepted. From 2005-06 also, the heading remains of synthetic monofilament yarn of 67 decitex or more. Therefore, from 2005-06 the Heading is not applicable to the appellants on the basis of the Chemical Examiners report.
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