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...
Commissioner (Appeals) allowed the re-export of goods - Customs authorities below did not release the goods for re-export thereby allowing the goods to further deteriorate in quality and in addition incurring huge demurrage due to lapse of considerable time for no fault of the respondent. - It is deemed appropriate to direct the Chief Commissioner of Customs, Delhi to hold necessary inquiry into the matter regarding the delay caused in not allowing the re-export of the goods and take appropriate action against the errant officials - AT
Commissioner (Appeals) allowed the re-export of goods - Customs authorities below did not release the goods for re-export thereby allowing the goods to further deteriorate in quality and in addition incurring huge demurrage due to lapse of considerable time for no fault of the respondent. - It is deemed appropriate to direct the Chief Commissioner of Customs, Delhi to hold necessary inquiry into the matter regarding the delay caused in not allowing the re-export of the goods and take appropriate action against the errant officials - AT
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