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...
Customs Cargo Service Provider (CCSP) - Suspension of their CCSP approval and imposing a penalty - Demand of value of pilfered goods - custodian of Speedy CFS - Cigarette sticks were found stolen / Pilfered from the safe custody - The CESTAT held that the suspension, subject to facilitating existing consignments, is valid under Handling of Cargo in Customs Areas Regulations (HCCAR), 2019. However, the specific suspension period had expired, making the order non-implementable. - The appellant violated obligations under Regulations 5(1)(i)(n), 6(1)(f), and 6(1)(i) of HCCAR, justifying the penalty under Regulation 12(8) and Section 117 of the Customs Act, 1962.
Customs Cargo Service Provider (CCSP) - Suspension of their CCSP approval and imposing a penalty - Demand of value of pilfered goods - custodian of Speedy CFS - Cigarette sticks were found stolen / Pilfered from the safe custody - The CESTAT held that the suspension, subject to facilitating existing consignments, is valid under Handling of Cargo in Customs Areas Regulations (HCCAR), 2019. However, the specific suspension period had expired, making the order non-implementable. - The appellant violated obligations under Regulations 5(1)(i)(n), 6(1)(f), and 6(1)(i) of HCCAR, justifying the penalty under Regulation 12(8) and Section 117 of the Customs Act, 1962.
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