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...
SION - starch slurry - maize - manufacturing of liquid glucose concentrate (food grade) - Recovery of customs duty foregone on the inputs allowed to be imported under 7 DFIA licences - In the present case, the immediate parent material was starch slurry i.e. starch and not maize and therefore case of the department that SION E76 was the correct norm cannot be sustained. Since the immediate parent material for manufacturing the exported goods was starch falling under SION E22 , it is clear that the Starch was the correctly applicable SION. - AT
SION - starch slurry - maize - manufacturing of liquid glucose concentrate (food grade) - Recovery of customs duty foregone on the inputs allowed to be imported under 7 DFIA licences - In the present case, the immediate parent material was starch slurry i.e. starch and not maize and therefore case of the department that SION E76 was the correct norm cannot be sustained. Since the immediate parent material for manufacturing the exported goods was starch falling under SION E22 , it is clear that the Starch was the correctly applicable SION. - AT
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