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...
Classification of imported goods - Turbochargers which are suitable for use only in Off-highway equipment i.e., for generators, earth moving equipment etc. - The AAR observed that, the Notification No. 50/2017, dated 30-6-2017, as amended makes it clear that turbochargers are chargeable for 7.5% duty instead of 15% provided the same are not used in motor vehicles/cars/cycles - According the advance ruling authority held that, the turbochargers will get benefit of the notification only in case where they are suitable for use in goods other than motor vehicles/cars/cycles falling under Headings 8702, 8703, 8704 and 8711.
Classification of imported goods - Turbochargers which are suitable for use only in Off-highway equipment i.e., for generators, earth moving equipment etc. - The AAR observed that, the Notification No. 50/2017, dated 30-6-2017, as amended makes it clear that turbochargers are chargeable for 7.5% duty instead of 15% provided the same are not used in motor vehicles/cars/cycles - According the advance ruling authority held that, the turbochargers will get benefit of the notification only in case where they are suitable for use in goods other than motor vehicles/cars/cycles falling under Headings 8702, 8703, 8704 and 8711.
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