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 114 of the Customs Act, 1962 on the owners of the seized goods - Allegation that, pulses (URAD ki Dal) in question were meant for illegal export from India to Nepal - Requirement to cross-examination of the witnesses. Genuineness of the Punchnama - panch witnesses are stated to be ‘daily wage laborers'. - The tribunal set aside the penalty in the absence of allowing cross-examination of witness.
Levy of penalty u/s 114 of the Customs Act, 1962 on the owners of the seized goods - Allegation that, pulses (URAD ki Dal) in question were meant for illegal export from India to Nepal - Requirement to cross-examination of the witnesses. Genuineness of the Punchnama - panch witnesses are stated to be ‘daily wage laborers'. - The tribunal set aside the penalty in the absence of allowing cross-examination of witness.
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