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...
Mis-declaration of imported goods - Heavy Melting Steel Scrap - The rate of duty is same. Moreover, the differential duty on enhancement value is CVD which is available to the appellant as Cenvat credit. When this is undisputed fact, we find that there is no malafide intention on the part of the appellant. However, it is admitted fact that description i.e. Heavy Melting Scrap was wrongly declared as against the actual material of Shredded Scrap. - Redemption fine and penalty reduced substantially - AT
Mis-declaration of imported goods - Heavy Melting Steel Scrap - The rate of duty is same. Moreover, the differential duty on enhancement value is CVD which is available to the appellant as Cenvat credit. When this is undisputed fact, we find that there is no malafide intention on the part of the appellant. However, it is admitted fact that description i.e. Heavy Melting Scrap was wrongly declared as against the actual material of Shredded Scrap. - Redemption fine and penalty reduced substantially - AT
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