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...
Maintainability of appeal - pre-deposit of the amount of certain percentage of duty demanded or penalty imposed - Perusal of section 35F of Central Excise Act, 1944 makes it apparent and clear that the requirement of this section is mandatory requirement and the failure thereof results in rejection of appeal ‘in limine’ - matter be remanded back to the Commissioner (Appeals) with the direction to the appellant to make good the absence of payment of amount of mandatory pre deposit prior for the appeal being heard by Commissioner (Appeals) - AT
Maintainability of appeal - pre-deposit of the amount of certain percentage of duty demanded or penalty imposed - Perusal of section 35F of Central Excise Act, 1944 makes it apparent and clear that the requirement of this section is mandatory requirement and the failure thereof results in rejection of appeal ‘in limine’ - matter be remanded back to the Commissioner (Appeals) with the direction to the appellant to make good the absence of payment of amount of mandatory pre deposit prior for the appeal being heard by Commissioner (Appeals) - AT
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