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...
Classification of goods - scrap-veg-refuse - The tribunal held that, the physical form of 'scrap-veg-refuse' as a wet paste differs from the white powdered form specified for potato starch. It notes that the presence of starch alone does not classify the product as potato starch and that sufficient evidence is needed to establish it as such. Additionally, the process of manufacturing potato starch differs significantly from the recycling process employed by the appellant. - Demand of duty set aside.
Classification of goods - scrap-veg-refuse - The tribunal held that, the physical form of 'scrap-veg-refuse' as a wet paste differs from the white powdered form specified for potato starch. It notes that the presence of starch alone does not classify the product as potato starch and that sufficient evidence is needed to establish it as such. Additionally, the process of manufacturing potato starch differs significantly from the recycling process employed by the appellant. - Demand of duty set aside.
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