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...
Benefit of exemption from customs duty - Change of Notification in the bill of entry - alternate exemption Notification - The Tribunal held that, the only criteria to be seen that whether at the time of import the alternate exemption notification was legally available to the appellant - In the facts of the present case, there is no dispute about eligibility of the Notification 94/2006-Cus in respect of the import made by the appellant as the goods were meant for re-export. - Further, by following the decision of Supreme Court, wherein it was held that the beneficial notification can be claimed at a later stage also, if otherwise the same is eligible at the time of import of goods, the CESTAT allowed the claim of the Importer.
Benefit of exemption from customs duty - Change of Notification in the bill of entry - alternate exemption Notification - The Tribunal held that, the only criteria to be seen that whether at the time of import the alternate exemption notification was legally available to the appellant - In the facts of the present case, there is no dispute about eligibility of the Notification 94/2006-Cus in respect of the import made by the appellant as the goods were meant for re-export. - Further, by following the decision of Supreme Court, wherein it was held that the beneficial notification can be claimed at a later stage also, if otherwise the same is eligible at the time of import of goods, the CESTAT allowed the claim of the Importer.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4800
Join Channel
TaxTMI 
