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...
Demanded of interest for the delayed payment of education cess - Education cess and secondary and higher education cess should not be included in the aggregate value for duties on DTA (Domestic Tariff Area) clearances by 100% EOUs (Export Oriented Units). The decision emphasized the principle of not charging a cess on the same tax base more than once, adhering to judicial discipline and the precedential value of the Larger Bench's ruling. - Demand set aside - AT
Demanded of interest for the delayed payment of education cess - Education cess and secondary and higher education cess should not be included in the aggregate value for duties on DTA (Domestic Tariff Area) clearances by 100% EOUs (Export Oriented Units). The decision emphasized the principle of not charging a cess on the same tax base more than once, adhering to judicial discipline and the precedential value of the Larger Bench's ruling. - Demand set aside - AT
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