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...
Conversion of shipping bills from Duty Drawback Scheme to DFIA Scheme - Period of limitation - they were held to be eligible to claim the benefit of DFIA. Section 149 of the Customs Act, 1962 lays down that any import/export document may be considered for conversion subject to satisfaction of the proper officer without having any limitation. - No time period is prescribed in Section 149 for conversion of bills and any policy providing for time period is ultra vires - HC
Conversion of shipping bills from Duty Drawback Scheme to DFIA Scheme - Period of limitation - they were held to be eligible to claim the benefit of DFIA. Section 149 of the Customs Act, 1962 lays down that any import/export document may be considered for conversion subject to satisfaction of the proper officer without having any limitation. - No time period is prescribed in Section 149 for conversion of bills and any policy providing for time period is ultra vires - HC
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