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...
Classification of the goods - preparation of Betel Nuts known as ‘Boiled Supari’ - Given the definition of the sub-heading “Betel nut product known as ‘Supari’”, read in the context of the main title of Chapter 21 and sub-heading 0802 read in the context with the title of Chapter 8 of the Customs Tariff (“Edible fruits and nuts; peel of citrus fruit or melons”); it would not be apposite to classify the products in question as those covered under Chapter 21 of the Customs Tariff. - HC
Classification of the goods - preparation of Betel Nuts known as ‘Boiled Supari’ - Given the definition of the sub-heading “Betel nut product known as ‘Supari’”, read in the context of the main title of Chapter 21 and sub-heading 0802 read in the context with the title of Chapter 8 of the Customs Tariff (“Edible fruits and nuts; peel of citrus fruit or melons”); it would not be apposite to classify the products in question as those covered under Chapter 21 of the Customs Tariff. - HC
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