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...
Clandestine removal - evasion of duty - clearance of branded Khaini - burden to prove on Revenue - Ultimately, the High court concurred with the majority view of the CESTAT, which had found the evidence against the respondents unreliable and insufficient to establish the charge of clandestine removal. The appeals filed by the Revenue were dismissed on the grounds that the allegations could not be substantiated beyond reasonable doubt, underscoring the need for tangible evidence to support claims of tax evasion and clandestine operations.
Clandestine removal - evasion of duty - clearance of branded Khaini - burden to prove on Revenue - Ultimately, the High court concurred with the majority view of the CESTAT, which had found the evidence against the respondents unreliable and insufficient to establish the charge of clandestine removal. The appeals filed by the Revenue were dismissed on the grounds that the allegations could not be substantiated beyond reasonable doubt, underscoring the need for tangible evidence to support claims of tax evasion and clandestine operations.
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