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 - HR Sheets, HR Plates and MS Rods used for fabrication of Steel Formers which is in the nature of a consumable in the Appellant’s induction furnace - the authorities below have categorically admitted that the impugned goods are used in the fabrication of Steel Former, which undisputedly gets consumed in the process of the Appellant’s manufacturing of finished goods. - Credit allowed - AT
CENVAT Credit - inputs - HR Sheets, HR Plates and MS Rods used for fabrication of Steel Formers which is in the nature of a consumable in the Appellant’s induction furnace - the authorities below have categorically admitted that the impugned goods are used in the fabrication of Steel Former, which undisputedly gets consumed in the process of the Appellant’s manufacturing of finished goods. - Credit allowed - AT
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