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...
Excess utilisation of cenvat credit - Whether the appellant is liable to pay interest and penalty on account of alleged excess utilisation of cenvat credit - The demand of interest on alleged excess utilisation of cenvat credit amounts to double demand of interest, as the appellant has already deposited interest on the delayed payment of tax at the applicable rate under Section 75 of the Act. Thus, the second demand of interest is in the nature of double jeopardy, which is not tenable - AT
Excess utilisation of cenvat credit - Whether the appellant is liable to pay interest and penalty on account of alleged excess utilisation of cenvat credit - The demand of interest on alleged excess utilisation of cenvat credit amounts to double demand of interest, as the appellant has already deposited interest on the delayed payment of tax at the applicable rate under Section 75 of the Act. Thus, the second demand of interest is in the nature of double jeopardy, which is not tenable - AT
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