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...
EOU - Non-fulfilment of export obligations - reasons beyond the control - The tribunal held that the appellant having not fulfilled the export obligation and not used the raw materials for manufacture of finished products for export, the exemption of the notification is not available. - The CESTAT partially allows the appeal, setting aside the demand for Special Additional Duty prior to a specific date pending verification. However, it upholds the duty liability and interest demands, except where modifications are specified.
EOU - Non-fulfilment of export obligations - reasons beyond the control - The tribunal held that the appellant having not fulfilled the export obligation and not used the raw materials for manufacture of finished products for export, the exemption of the notification is not available. - The CESTAT partially allows the appeal, setting aside the demand for Special Additional Duty prior to a specific date pending verification. However, it upholds the duty liability and interest demands, except where modifications are specified.
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