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...
Amendment of bills of entry - The High court examined Section 149 of the Customs Act, which permits amendments of import documents under certain conditions. - HD found that the first proviso to Section 149 allows amendments even after goods are cleared for home consumption, subject to the condition of existence of documentary evidence at the time of clearance. - As regards the requirement that the importer should establish that the goods originated from Australia, as discussed earlier, this aspect should be determined by examining the certificate of origin and any other relevant documents. - Matter restored back.
Amendment of bills of entry - The High court examined Section 149 of the Customs Act, which permits amendments of import documents under certain conditions. - HD found that the first proviso to Section 149 allows amendments even after goods are cleared for home consumption, subject to the condition of existence of documentary evidence at the time of clearance. - As regards the requirement that the importer should establish that the goods originated from Australia, as discussed earlier, this aspect should be determined by examining the certificate of origin and any other relevant documents. - Matter restored back.
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