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...
Classification of goods - There is no doubt that the Hon’ble Supreme Court did not render a finality to the dispute over classification but the Tribunal, indubitably, has. That finality can be shaken only by a reversal in the highest court of the land and, until then, the law settled by the Tribunal prevails; failure to recognise that finality places orders of original authority and first appellate authorities in peril and for consequences of breach of discipline. - AT
Classification of goods - There is no doubt that the Hon’ble Supreme Court did not render a finality to the dispute over classification but the Tribunal, indubitably, has. That finality can be shaken only by a reversal in the highest court of the land and, until then, the law settled by the Tribunal prevails; failure to recognise that finality places orders of original authority and first appellate authorities in peril and for consequences of breach of discipline. - AT
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