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...
Levy of penalty u/s 112(a) of the Customs Act, 1962 on an employee of the Customs Broker - classification of imported goods - The commissioner has recorded as finding that responsibility for proper declaration of the goods lies with the importer and having sought for examination of the goods before assessment, there was no element of mis-declaration on the part of customs broker and the employee (appellant) attracting imposition of penalty u/s 112(a) - However, commissioner levied penalty on the ground that, employee of CB did not advise the importer to classify the goods correctly - Tribunal deleted the penalty.
Levy of penalty u/s 112(a) of the Customs Act, 1962 on an employee of the Customs Broker - classification of imported goods - The commissioner has recorded as finding that responsibility for proper declaration of the goods lies with the importer and having sought for examination of the goods before assessment, there was no element of mis-declaration on the part of customs broker and the employee (appellant) attracting imposition of penalty u/s 112(a) - However, commissioner levied penalty on the ground that, employee of CB did not advise the importer to classify the goods correctly - Tribunal deleted the penalty.
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