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 imported goods - change in the stand of revenue during the appellate proceedings - The approach of the Revenue who have chosen to file the present appeal for the reasons that as and when the Order-in-Original was received, they slept over the matter and thus missed the bus. Secondly, having not exhausted the available opportunity, they have contended that the Commissioner (Appeals) should have, on his own, exercised power under Section 128A (3) which, according to us, does not stand - AT
Classification of imported goods - change in the stand of revenue during the appellate proceedings - The approach of the Revenue who have chosen to file the present appeal for the reasons that as and when the Order-in-Original was received, they slept over the matter and thus missed the bus. Secondly, having not exhausted the available opportunity, they have contended that the Commissioner (Appeals) should have, on his own, exercised power under Section 128A (3) which, according to us, does not stand - AT
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