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...
CENVAT Credit - common inputs/input services used for manufacture of stock transferred exempted goods (lime stone) and dutiable products (Cement/Clinker) - The Tribunal clarified that the presence of two different final products (limestone as exempted and cement/clinker as dutiable) necessitates the maintenance of separate accounts for inputs/input services used. The court rejected the appellant's interpretation and emphasized that the rules apply to their situation, thus upholding the demand for payment under Rule 6(3)(i) due to the appellant's failure to maintain separate accounts. - However, the CESTAT agreed with the appellant regarding the limitation period, noting no grounds for invoking the extended period due to the appellant's transparent documentation and periodic disclosures.
CENVAT Credit - common inputs/input services used for manufacture of stock transferred exempted goods (lime stone) and dutiable products (Cement/Clinker) - The Tribunal clarified that the presence of two different final products (limestone as exempted and cement/clinker as dutiable) necessitates the maintenance of separate accounts for inputs/input services used. The court rejected the appellant's interpretation and emphasized that the rules apply to their situation, thus upholding the demand for payment under Rule 6(3)(i) due to the appellant's failure to maintain separate accounts. - However, the CESTAT agreed with the appellant regarding the limitation period, noting no grounds for invoking the extended period due to the appellant's transparent documentation and periodic disclosures.
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