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...
Warehoused goods - warehousing period expired - goods (wine) was rendered unfit for human consumption - relinquishment to the title to goods - The appellant is not liable to pay duty, as till the time of relinquishment, no duty or other charges had been demanded from them. However, in the circumstances, as the appellant have also allowed the goods to deteriorate by not taking action timely to relinquish the goods within a reasonable time, they are held liable to penalty - penalty under Section 117 is imposed instead of Section 112 - reduced penalty of Rs. 1 Lakh is confirmed. - AT
Warehoused goods - warehousing period expired - goods (wine) was rendered unfit for human consumption - relinquishment to the title to goods - The appellant is not liable to pay duty, as till the time of relinquishment, no duty or other charges had been demanded from them. However, in the circumstances, as the appellant have also allowed the goods to deteriorate by not taking action timely to relinquish the goods within a reasonable time, they are held liable to penalty - penalty under Section 117 is imposed instead of Section 112 - reduced penalty of Rs. 1 Lakh is confirmed. - AT
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