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...
Rejection of request of conversion of DFIA Shipping Bill to DBK - rejection on the ground of limitation as prescribed under Board Circular No. 36/2010-Cus dated 23.09.2010 - The Tribunal held that, the rejection of the appellant’s request for conversion of DFIA Scheme to DBK Scheme in shipping is absolutely illegal and incorrect.
Rejection of request of conversion of DFIA Shipping Bill to DBK - rejection on the ground of limitation as prescribed under Board Circular No. 36/2010-Cus dated 23.09.2010 - The Tribunal held that, the rejection of the appellant’s request for conversion of DFIA Scheme to DBK Scheme in shipping is absolutely illegal and incorrect.
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