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...
Seizure of goods alongwith the vehicle - The imposition of the penal consequences due to an exception, which has been caused on account of the inadvertent human error by not referring the invoice number as “SAI/V-235” and by referring it to “235” only. Since even the invoice number “235” has been consistently maintained in all the documentations, which were made by the petitioner, since it never cleverly intended to evade the tax, or revenue of the State, the exception would fall to be within Clause 5 of the Circular - the imposition made on account of the said human error, which has crept in in invoice number is pardonable under Clause 5 of the Circular - HC
Seizure of goods alongwith the vehicle - The imposition of the penal consequences due to an exception, which has been caused on account of the inadvertent human error by not referring the invoice number as “SAI/V-235” and by referring it to “235” only. Since even the invoice number “235” has been consistently maintained in all the documentations, which were made by the petitioner, since it never cleverly intended to evade the tax, or revenue of the State, the exception would fall to be within Clause 5 of the Circular - the imposition made on account of the said human error, which has crept in in invoice number is pardonable under Clause 5 of the Circular - HC
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