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...
Valuation of imported goods - contemporaneous imports - The tribunal observed that the Revenue had not provided adequate evidence or a proper comparison with contemporaneous imports to justify the revaluation of the imported goods' declared value. The lack of such comparison and evidence in revaluation matters was a key factor in the tribunal's decision to set aside the impugned order and allow the appellant's appeal. - AT
Valuation of imported goods - contemporaneous imports - The tribunal observed that the Revenue had not provided adequate evidence or a proper comparison with contemporaneous imports to justify the revaluation of the imported goods' declared value. The lack of such comparison and evidence in revaluation matters was a key factor in the tribunal's decision to set aside the impugned order and allow the appellant's appeal. - AT
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