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...
Imports crude edible oil - crude palm oil - Whether Social Welfare Surcharge (SWS) is leviable when the Basic Customs Duty (BCD) is exempted. - The tribunal held that since the BCD is exempted, and as SWS is calculated at the rate of 10% on the aggregate of duties, taxes, and cesses levied and collected, which in this case is nil, SWS is also nil. The tribunal found no provision for calculation of SWS on notional BCD when actual BCD is exempted.
Imports crude edible oil - crude palm oil - Whether Social Welfare Surcharge (SWS) is leviable when the Basic Customs Duty (BCD) is exempted. - The tribunal held that since the BCD is exempted, and as SWS is calculated at the rate of 10% on the aggregate of duties, taxes, and cesses levied and collected, which in this case is nil, SWS is also nil. The tribunal found no provision for calculation of SWS on notional BCD when actual BCD is exempted.
Note: It is a system-generated summary and is for quick reference only.