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...
Process amounting to manufacture or not - activity of “labelling or relabeling, declaration by affixing fresh Maximum Retail Price (MRP) stickers” on each unit pack, by altering the retail price stickers already affixed on the watches - The tribunal concluded that relabeling and affixing new MRP stickers do not amount to manufacture. It relied on precedents stating that such activities, not enhancing the goods' marketability, do not meet the manufacture criteria under the Excise Act. - The tribunal supported the appellants' view that Section 2(f)(iii) does not apply to goods manufactured under ABE, as applying the concept of deemed manufacture to such goods would counteract the exemption's intent.
Process amounting to manufacture or not - activity of “labelling or relabeling, declaration by affixing fresh Maximum Retail Price (MRP) stickers” on each unit pack, by altering the retail price stickers already affixed on the watches - The tribunal concluded that relabeling and affixing new MRP stickers do not amount to manufacture. It relied on precedents stating that such activities, not enhancing the goods' marketability, do not meet the manufacture criteria under the Excise Act. - The tribunal supported the appellants' view that Section 2(f)(iii) does not apply to goods manufactured under ABE, as applying the concept of deemed manufacture to such goods would counteract the exemption's intent.
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