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...
Classification of goods - Alexa voice remote - the contention of the applicant that Alexa voice remote (3rd Gen) does not merit classification as radio remote control apparatus under 8526 92 00 since it uses Bluetooth technology is facile and not accepted - the appropriate classification of Alexa voice remote (3rd Gen) based on rule 1 and rule 3(b) of GI Rules is under CTH 8526, and specifically under sub-heading 85269200. - AAR
Classification of goods - Alexa voice remote - the contention of the applicant that Alexa voice remote (3rd Gen) does not merit classification as radio remote control apparatus under 8526 92 00 since it uses Bluetooth technology is facile and not accepted - the appropriate classification of Alexa voice remote (3rd Gen) based on rule 1 and rule 3(b) of GI Rules is under CTH 8526, and specifically under sub-heading 85269200. - AAR
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