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...
Effective Date of Notification - Prescribing tariff value prescribed therein, for the earlier import of R.B.D. Palmolein oil - The High Court noted that in an earlier case the Division Bench had clarified that the notification would be enforceable only from the date it was notified and published in the Official Gazette, i.e., on 06.08.2001. Therefore, any liability accruing from that notification would be applicable only from that date onwards, not from 03.08.2001.
Effective Date of Notification - Prescribing tariff value prescribed therein, for the earlier import of R.B.D. Palmolein oil - The High Court noted that in an earlier case the Division Bench had clarified that the notification would be enforceable only from the date it was notified and published in the Official Gazette, i.e., on 06.08.2001. Therefore, any liability accruing from that notification would be applicable only from that date onwards, not from 03.08.2001.
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