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 - waste/by-product generated i.e. Aluminium dross during the manufacture of Aluminium products from Alumina in the appellant's factory which is sold by the appellant without payment of duty - exempt goods or not - The Tribunal allowed the appeal, holding that the appellant is not liable to pay excise duty on the clearance of "Aluminium dross" based on several grounds. - The order under challenge erred in applying Rule 6 of CCR, 2004 based on the rescinded circular, and the Commissioner (Appeals) failed to consider the implications of the Supreme Court's decision in Sucrose India (supra) and the Circular dated 07.07.2022.
CENVAT Credit - waste/by-product generated i.e. Aluminium dross during the manufacture of Aluminium products from Alumina in the appellant's factory which is sold by the appellant without payment of duty - exempt goods or not - The Tribunal allowed the appeal, holding that the appellant is not liable to pay excise duty on the clearance of "Aluminium dross" based on several grounds. - The order under challenge erred in applying Rule 6 of CCR, 2004 based on the rescinded circular, and the Commissioner (Appeals) failed to consider the implications of the Supreme Court's decision in Sucrose India (supra) and the Circular dated 07.07.2022.
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