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...
Levy of penalty u/s 114 of the Customs Act - appellant is a freight forwarder - export of non-basmati rice - prohibited goods or not - admittedly in the course of various statements recorded on different dates from this appellant he has admitted the modus operandi and have stated in detail the modus operandi as well as the amount of remuneration he was getting from the Exporter, which leads to the conclusion that he had connived with the Exporter in the export of prohibited goods for money. - Levy of penalty confirmed at reduced amount - AT
Levy of penalty u/s 114 of the Customs Act - appellant is a freight forwarder - export of non-basmati rice - prohibited goods or not - admittedly in the course of various statements recorded on different dates from this appellant he has admitted the modus operandi and have stated in detail the modus operandi as well as the amount of remuneration he was getting from the Exporter, which leads to the conclusion that he had connived with the Exporter in the export of prohibited goods for money. - Levy of penalty confirmed at reduced amount - AT
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