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...
Quantum of redemption fine and penalty - import of used digital multifunction machines - mis-declaration of value of goods - Considering the fact that the Department has also accepted the same in the case of M/s. Accord Digitech v. C.C., Bangalore, the tribunal held that in the interest of justice since 6 years have already been lapsed, the present appeal is partially allowed by reducing the redemption fine and penalty by 10% and 5% respectively of the enhanced value.
Quantum of redemption fine and penalty - import of used digital multifunction machines - mis-declaration of value of goods - Considering the fact that the Department has also accepted the same in the case of M/s. Accord Digitech v. C.C., Bangalore, the tribunal held that in the interest of justice since 6 years have already been lapsed, the present appeal is partially allowed by reducing the redemption fine and penalty by 10% and 5% respectively of the enhanced value.
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