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...
Cancellation of the MEIS Scrips granted to the Respondent Company confirmed - levy of penalty - The initial supply of goods by the exporter to a logistics company is purely facilitative, for the purpose of convenience. Therefore, the relevant provisions of the FTP dealing with MEIS Scrips cannot be interpreted in a manner that permits secondary facilitative transactions to supplant the principal export transaction thus preventing actual exporters from obtaining the benefit of MEIS Scrips. - The order of revalidation of the MEIS Scrips is correct - HC
Cancellation of the MEIS Scrips granted to the Respondent Company confirmed - levy of penalty - The initial supply of goods by the exporter to a logistics company is purely facilitative, for the purpose of convenience. Therefore, the relevant provisions of the FTP dealing with MEIS Scrips cannot be interpreted in a manner that permits secondary facilitative transactions to supplant the principal export transaction thus preventing actual exporters from obtaining the benefit of MEIS Scrips. - The order of revalidation of the MEIS Scrips is correct - HC
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