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...
MEIS scheme - denial of benefit of section 149 of the Customs Act, 1962 - Amendment to shipping bills - The argument on behalf of the Revenue is that once the goods are exported, it is very difficult thereafter to undertake proper verification or rather physical verification of the goods even for the purpose of amendment in the shipping bills. The argument is that almost after a period of 2 years from the date of export, the assesee has claimed amendment in the shipping bills. - HC
MEIS scheme - denial of benefit of section 149 of the Customs Act, 1962 - Amendment to shipping bills - The argument on behalf of the Revenue is that once the goods are exported, it is very difficult thereafter to undertake proper verification or rather physical verification of the goods even for the purpose of amendment in the shipping bills. The argument is that almost after a period of 2 years from the date of export, the assesee has claimed amendment in the shipping bills. - HC
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