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 imported goods - poultry Feed Milling machinery - to be classified under CTH 9406 00 93 or under CTH 8436 10 00? - there is direct entry at CTH 8436 which speaks of machineries used in poultry keeping - there is no categorical assertion that the goods in question fall under “silos”. Further there is nothing to show by way of evidence that the imported goods have been used for “storing ensilage”. Therefore, the classification arrived at by the Adjudicating Authority cannot be agreed upon. - AT
Classification of imported goods - poultry Feed Milling machinery - to be classified under CTH 9406 00 93 or under CTH 8436 10 00? - there is direct entry at CTH 8436 which speaks of machineries used in poultry keeping - there is no categorical assertion that the goods in question fall under “silos”. Further there is nothing to show by way of evidence that the imported goods have been used for “storing ensilage”. Therefore, the classification arrived at by the Adjudicating Authority cannot be agreed upon. - AT
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