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...
Seeking provisional release of the export consignment - Once the reasoned order for provisional released has been passed in respect of the relevant consignment under the provisions of section 110A of the said Act and the conditions for such provisional release have been complied with by the applicant/petitioner, we fail to comprehend as to how such an administrative order could be cited as a precedent in future cases so as to preclude us from making an order as prayed for in the interim application. - HC
Seeking provisional release of the export consignment - Once the reasoned order for provisional released has been passed in respect of the relevant consignment under the provisions of section 110A of the said Act and the conditions for such provisional release have been complied with by the applicant/petitioner, we fail to comprehend as to how such an administrative order could be cited as a precedent in future cases so as to preclude us from making an order as prayed for in the interim application. - HC
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