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...
Demand of custom duty - Period of limitation - The 39 Bills of Entries were filed during the period of August, 1996 to January, 2004. The Show Cause Notice dated 06.03.2013, has been issued approximately nine years after the last Bill of Entry. In the given facts, we are unable to accept that the appellant had issued the notice within a reasonable period. - HC
Demand of custom duty - Period of limitation - The 39 Bills of Entries were filed during the period of August, 1996 to January, 2004. The Show Cause Notice dated 06.03.2013, has been issued approximately nine years after the last Bill of Entry. In the given facts, we are unable to accept that the appellant had issued the notice within a reasonable period. - HC
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