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...
Confiscation of the imported machinery under the EPCG scheme - the DGFT, by granting extension for fulfilment of export obligation, have condoned the delay in achieving the export obligations and have also regularised the shifting of the machinery to the new address. However, such extension remained mere formality or an eye wash, as the appellant did not have any opportunity to manufacture and export pursuant to granting of extension in March, 2018, as the machines were admittedly lying sealed by the Customs Department since 2016. - the machines shall be de-sealed with the immediate effect - AT
Confiscation of the imported machinery under the EPCG scheme - the DGFT, by granting extension for fulfilment of export obligation, have condoned the delay in achieving the export obligations and have also regularised the shifting of the machinery to the new address. However, such extension remained mere formality or an eye wash, as the appellant did not have any opportunity to manufacture and export pursuant to granting of extension in March, 2018, as the machines were admittedly lying sealed by the Customs Department since 2016. - the machines shall be de-sealed with the immediate effect - AT
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