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...
Confiscation of imported goods - multi-functional devices - requirement to meet the standards as 'printers / plotters' as per Electronics & Information Technology Goods - The Tribunal upheld the redemption for home consumption of the goods, rejecting the Revenue's contentions. The Andhra Pradesh High Court also addressed similar issues in previous cases, finding no reason to withhold later consignments after previous consignments had been released upon payment of penalties. - The High Court, in line with the Tribunal's findings and the precedent set by the Andhra Pradesh High Court, dismissed the batch of appeals filed by the Revenue, keeping the questions of law open.
Confiscation of imported goods - multi-functional devices - requirement to meet the standards as 'printers / plotters' as per Electronics & Information Technology Goods - The Tribunal upheld the redemption for home consumption of the goods, rejecting the Revenue's contentions. The Andhra Pradesh High Court also addressed similar issues in previous cases, finding no reason to withhold later consignments after previous consignments had been released upon payment of penalties. - The High Court, in line with the Tribunal's findings and the precedent set by the Andhra Pradesh High Court, dismissed the batch of appeals filed by the Revenue, keeping the questions of law open.
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