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...
Correctness of erasure of credit already availed by prospective invalidation of eligibility for retention of credit that would subject those services already procured and used in manufacture/rendering of services to the test of eligibility once again - deletion of rule 6(5) of CENVAT Credit Rules, 2004 with effect from 31st March 2011 - The Tribunal emphasizes that the deletion of rule 6(5) does not affect the validity of credit availed under rule 3 of the CENVAT Credit Rules, 2004, at the time of procurement of services. - It concludes that the appellant's entitlement to credit cannot be curtailed or impacted by the deletion of rule 6(5), and the impugned order is not sustainable.
Correctness of erasure of credit already availed by prospective invalidation of eligibility for retention of credit that would subject those services already procured and used in manufacture/rendering of services to the test of eligibility once again - deletion of rule 6(5) of CENVAT Credit Rules, 2004 with effect from 31st March 2011 - The Tribunal emphasizes that the deletion of rule 6(5) does not affect the validity of credit availed under rule 3 of the CENVAT Credit Rules, 2004, at the time of procurement of services. - It concludes that the appellant's entitlement to credit cannot be curtailed or impacted by the deletion of rule 6(5), and the impugned order is not sustainable.
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