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...
Exemption from payment of whole of Customs duty - failure to re-export 39 containers within the period of six months prescribed in the said notification purportedly due to some fire on the port and damage to other containers - The tribunal held that, there was clearly a breach of condition of exemption notification and in the absence of any remission or waiver of duty having been granted by the competent authorities and the same not having been sought by the party for considerable length of time. - Thus while confirming the demand of duty, the CESTAT remanded back the matter on the ground of valuation with full transparency.
Exemption from payment of whole of Customs duty - failure to re-export 39 containers within the period of six months prescribed in the said notification purportedly due to some fire on the port and damage to other containers - The tribunal held that, there was clearly a breach of condition of exemption notification and in the absence of any remission or waiver of duty having been granted by the competent authorities and the same not having been sought by the party for considerable length of time. - Thus while confirming the demand of duty, the CESTAT remanded back the matter on the ground of valuation with full transparency.
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