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...
Maintainability of appeal - appropriate forum - High Court or Supreme Court - question is/was whether the respondents can be said to be manufacture of stators or not and therefore liable to pay central excise duty or not. - In the instant case, the dispute has no relation to the rate of duty or the value of the goods - the High Court has committed a very serious error in not entertaining the appeals and relegating the Revenue to prefer the appeals before this Court. - SC
Maintainability of appeal - appropriate forum - High Court or Supreme Court - question is/was whether the respondents can be said to be manufacture of stators or not and therefore liable to pay central excise duty or not. - In the instant case, the dispute has no relation to the rate of duty or the value of the goods - the High Court has committed a very serious error in not entertaining the appeals and relegating the Revenue to prefer the appeals before this Court. - SC
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