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...
Method of Valuation - section 4 of Central Excise Act, 1944 or section 4A of Central Excise Act, 1944 - packages of cake mixes manufactured having been affixed with retail sale price (RSP) - The tribunal held that, for the period before the Legal Metrology (Packaged Commodities) Rules, 2011, goods not intended for retail sale (as indicated by the appellant) did not qualify for section 4A assessment based on RSP. - The tribunal upheld the demand for differential duty for the period prior to 1st April 2011, siding with the respondent on the assessment method. For the period after 1st April 2011, it set aside the demand, recognizing the expanded scope of section 4A.
Method of Valuation - section 4 of Central Excise Act, 1944 or section 4A of Central Excise Act, 1944 - packages of cake mixes manufactured having been affixed with retail sale price (RSP) - The tribunal held that, for the period before the Legal Metrology (Packaged Commodities) Rules, 2011, goods not intended for retail sale (as indicated by the appellant) did not qualify for section 4A assessment based on RSP. - The tribunal upheld the demand for differential duty for the period prior to 1st April 2011, siding with the respondent on the assessment method. For the period after 1st April 2011, it set aside the demand, recognizing the expanded scope of section 4A.
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