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...
Excisability - repacking the tobacco products by scenting - High Court is not an Expert Body in order to form an opinion with regard to the manufacturing of a product or otherwise. Experts in the Department must conduct an inspection and form an opinion, whether it is a manufacture of product or the raw material is just repacked and sold to the end user. The said nature of proceedings cannot be adjudicated before the High Court, as the scope of the writ proceedings are limited - HC
Excisability - repacking the tobacco products by scenting - High Court is not an Expert Body in order to form an opinion with regard to the manufacturing of a product or otherwise. Experts in the Department must conduct an inspection and form an opinion, whether it is a manufacture of product or the raw material is just repacked and sold to the end user. The said nature of proceedings cannot be adjudicated before the High Court, as the scope of the writ proceedings are limited - HC
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