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...
Valuation of imported goods - rejection of declared value - enhancement of value - The CESTAT held that since the appellant had voluntarily waived the right to a show cause notice and a personal hearing, and had accepted the enhanced value, the customs authorities were not required to follow the sequential procedure for valuation under the 2007 Valuation Rules. - The Tribunal did not accept the argument that the duty on the enhanced value was paid under duress, noting that the appellant had voluntarily accepted the enhanced value.
Valuation of imported goods - rejection of declared value - enhancement of value - The CESTAT held that since the appellant had voluntarily waived the right to a show cause notice and a personal hearing, and had accepted the enhanced value, the customs authorities were not required to follow the sequential procedure for valuation under the 2007 Valuation Rules. - The Tribunal did not accept the argument that the duty on the enhanced value was paid under duress, noting that the appellant had voluntarily accepted the enhanced value.
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