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...
CENVAT Credit - inputs issued for production lying in shop floor but not used for the production and the same was destroyed in fire - remission of duty granted - though the input was not used and issued for production, the demand of Cenvat Credit thereon was set aside - the demand of Cenvat Credit in respect of inputs issued for production and lying in shop floor is not sustainable - AT
CENVAT Credit - inputs issued for production lying in shop floor but not used for the production and the same was destroyed in fire - remission of duty granted - though the input was not used and issued for production, the demand of Cenvat Credit thereon was set aside - the demand of Cenvat Credit in respect of inputs issued for production and lying in shop floor is not sustainable - AT
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