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...
Absolute Confiscation - cash seized from the residential premise of Director of M/s PML and from the residence of alleged broker/agent for cenvatable invoices - When two authorities of the Department i.e. the Adjudicating Authority as well as the Appellate Authority have given categorical findings against the allegations made in the show cause notice giving cogent reasons, the Department is attempting to take the issue back to the beginning by filing these appeals. The Department has not made any case for confiscation of cash seized - AT
Absolute Confiscation - cash seized from the residential premise of Director of M/s PML and from the residence of alleged broker/agent for cenvatable invoices - When two authorities of the Department i.e. the Adjudicating Authority as well as the Appellate Authority have given categorical findings against the allegations made in the show cause notice giving cogent reasons, the Department is attempting to take the issue back to the beginning by filing these appeals. The Department has not made any case for confiscation of cash seized - AT
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