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...
Clandestine removal - double jeopardy - Both the show cause notices have alleged different offences to have been committed by the appellants, which are punishable under different provisions of the law - Penalty for both the show cause notices irrespective that they are arising out of the same transaction of acts cannot be called as double jeopardy.
Clandestine removal - double jeopardy - Both the show cause notices have alleged different offences to have been committed by the appellants, which are punishable under different provisions of the law - Penalty for both the show cause notices irrespective that they are arising out of the same transaction of acts cannot be called as double jeopardy.
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