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 goods - chlorinated paraffin - It is a settled law that any clarification with regard to any Act will always have retrospective effect for the reason that there is no change in the law but the existing law has been interpreted and clarified, therefore, the geneses of law remained intact. Accordingly, any clarification issued shall have a retrospective effect right from the enactment of the relevant law - revenue could not succeed in classifying the goods i.e. Chlorinated Paraffin in liquid form under Sub heading No. 2712 20 10. - AT
Classification of goods - chlorinated paraffin - It is a settled law that any clarification with regard to any Act will always have retrospective effect for the reason that there is no change in the law but the existing law has been interpreted and clarified, therefore, the geneses of law remained intact. Accordingly, any clarification issued shall have a retrospective effect right from the enactment of the relevant law - revenue could not succeed in classifying the goods i.e. Chlorinated Paraffin in liquid form under Sub heading No. 2712 20 10. - AT
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