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...
Clandestine Removal - mild steel ingots from sponge iron - pig iron - There is no explanation forthcoming in the impugned orders for discarding of the energy consumption determined during the trial production except to cast doubts by relying upon reports that, admittedly, did not test the furnace deployed by the appellant-assessee - the singular continuity of adjudicatory evaluation from the earlier period, discarded by the Tribunal in the appeal of the very same assessee and individual, to the present demand, the impugned order is bereft of sufficient facts and evidence to be sustained in appellate proceeding. - AT
Clandestine Removal - mild steel ingots from sponge iron - pig iron - There is no explanation forthcoming in the impugned orders for discarding of the energy consumption determined during the trial production except to cast doubts by relying upon reports that, admittedly, did not test the furnace deployed by the appellant-assessee - the singular continuity of adjudicatory evaluation from the earlier period, discarded by the Tribunal in the appeal of the very same assessee and individual, to the present demand, the impugned order is bereft of sufficient facts and evidence to be sustained in appellate proceeding. - AT
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