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...
Power of Commissioner (appeals) - appeal was considered on merit and directions were issued to the lower authority for re-assessing the Bills of Entry with consequential relief - Certain amendments were carried out to Section 128 of Customs Act,1962 w.e.f.29.03.2018 by the Finance Act, 2018. The effect of amendment was that the Commissioner (Appeals) was empowered under the statute to refer the matter back to the adjudicating authority with direction for fresh adjudication or decision, concerning the situation, where no order or decision has been passed after reassessment under Section 17ibid. - AT
Power of Commissioner (appeals) - appeal was considered on merit and directions were issued to the lower authority for re-assessing the Bills of Entry with consequential relief - Certain amendments were carried out to Section 128 of Customs Act,1962 w.e.f.29.03.2018 by the Finance Act, 2018. The effect of amendment was that the Commissioner (Appeals) was empowered under the statute to refer the matter back to the adjudicating authority with direction for fresh adjudication or decision, concerning the situation, where no order or decision has been passed after reassessment under Section 17ibid. - AT
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