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...
Flexi Tank Containers - Benefit of exemption on import - durable goods or not - entire emphasis of the Revenue is that the subject Flexi Tank Containers are not repeatedly used - Only because the containers do not have repeated use, the containers which are otherwise durable benefit of notification cannot be denied - AT
Flexi Tank Containers - Benefit of exemption on import - durable goods or not - entire emphasis of the Revenue is that the subject Flexi Tank Containers are not repeatedly used - Only because the containers do not have repeated use, the containers which are otherwise durable benefit of notification cannot be denied - AT
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