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...
Permission for provisional release of the goods - ball-bearings - The goods in question are subject matter of one bill of entry. Show cause notice itself, although is issued on 22nd April 2022 for almost one year has not been adjudicated and in fact, appears to have not progressed at all - a situation cannot be permitted where the Petitioner would suffer on both the counts at the hands of Commissioner of Customs - There is no acceptable reason that the petitioner in law should be denied provisional release on conditions. - HC
Permission for provisional release of the goods - ball-bearings - The goods in question are subject matter of one bill of entry. Show cause notice itself, although is issued on 22nd April 2022 for almost one year has not been adjudicated and in fact, appears to have not progressed at all - a situation cannot be permitted where the Petitioner would suffer on both the counts at the hands of Commissioner of Customs - There is no acceptable reason that the petitioner in law should be denied provisional release on conditions. - HC
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