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...
Conversion of Shipping bill under Drawback scheme to Advance Authorisation scheme - Condition provided in Board's Circular No. 36/2010 - Payment of customs duties on goods exported - The CESTAT observed that, Adjudicating authority concluded that the Appellant was not diligent in maintaining the records and on that ground, the request for amendment is denied. However as per the finding in the order, when certain omissions were brought to the notice of the Appellant, they have verified the records and rectified the same and therefore it cannot be concluded as they are not diligent in maintaining the records. - Thus, the impugned order rejecting the request for conversion of the shipping bill based on the Circular No.36/2010 is set aside.
Conversion of Shipping bill under Drawback scheme to Advance Authorisation scheme - Condition provided in Board's Circular No. 36/2010 - Payment of customs duties on goods exported - The CESTAT observed that, Adjudicating authority concluded that the Appellant was not diligent in maintaining the records and on that ground, the request for amendment is denied. However as per the finding in the order, when certain omissions were brought to the notice of the Appellant, they have verified the records and rectified the same and therefore it cannot be concluded as they are not diligent in maintaining the records. - Thus, the impugned order rejecting the request for conversion of the shipping bill based on the Circular No.36/2010 is set aside.
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