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...
Jurisdiction to pass an adjudication order - monetary limit - Power of adjudication prescribed by the Board vide a Circular dated 19/02/2008 is only an administrative order and it is meant for smooth and efficient running of the administration. Such circular cannot take away the power vested on a Central Excise officer under the provisions of the Central Excise Act. - AT
Jurisdiction to pass an adjudication order - monetary limit - Power of adjudication prescribed by the Board vide a Circular dated 19/02/2008 is only an administrative order and it is meant for smooth and efficient running of the administration. Such circular cannot take away the power vested on a Central Excise officer under the provisions of the Central Excise Act. - AT
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