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...
Conduct of the Customs officers - The Commissioner of Customs needs to look into such approach of the officers and not take it lightly so as to prevent a likelihood that such officers for reasons best known to them acting contrary to the binding orders passed by this Court and this is one of such cases. In these circumstances, it is requested that the Commissioner of Customs to look into the issue on understanding of the legal matters by such officers as in the present case wherein the Assistant Commissioner has totally discarded to consider the binding effect of the orders of this Court. - HC
Conduct of the Customs officers - The Commissioner of Customs needs to look into such approach of the officers and not take it lightly so as to prevent a likelihood that such officers for reasons best known to them acting contrary to the binding orders passed by this Court and this is one of such cases. In these circumstances, it is requested that the Commissioner of Customs to look into the issue on understanding of the legal matters by such officers as in the present case wherein the Assistant Commissioner has totally discarded to consider the binding effect of the orders of this Court. - HC
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