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...
Confiscation of the imported goods - used hand tools - "Capital Goods" or not as per para-9.12 of Foreign Trade Policy - appellant did not have licence to import such goods - The Tribunal referred to the earlier decision in the Asia Power Projects Ltd. case and concluded that the definition of "capital goods" in para 9.12 of FTP did not specifically mention "hand tools," but it encompassed a wide range of equipment, including instruments - Consequently, the Tribunal held that the imported hand tools fell within the definition of "capital goods".
Confiscation of the imported goods - used hand tools - "Capital Goods" or not as per para-9.12 of Foreign Trade Policy - appellant did not have licence to import such goods - The Tribunal referred to the earlier decision in the Asia Power Projects Ltd. case and concluded that the definition of "capital goods" in para 9.12 of FTP did not specifically mention "hand tools," but it encompassed a wide range of equipment, including instruments - Consequently, the Tribunal held that the imported hand tools fell within the definition of "capital goods".
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