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...
Pre-Deposit - Adjustment of various deposits made by entities during the course of investigation - The appellant argued that since they were associated with these entities and deposits were made with No Objection Certificates, these amounts should be adjusted for the pre-deposit requirement. However, the High court upheld the decision of the CESTAT, emphasizing that Section 129E places the responsibility of pre-deposit solely on the appellant, and deposits made by other entities cannot be considered for this purpose. The court's decision was based on the clear language of the provision, and it found no reason to interfere with the CESTAT's order. Thus, the appeal was dismissed.
Pre-Deposit - Adjustment of various deposits made by entities during the course of investigation - The appellant argued that since they were associated with these entities and deposits were made with No Objection Certificates, these amounts should be adjusted for the pre-deposit requirement. However, the High court upheld the decision of the CESTAT, emphasizing that Section 129E places the responsibility of pre-deposit solely on the appellant, and deposits made by other entities cannot be considered for this purpose. The court's decision was based on the clear language of the provision, and it found no reason to interfere with the CESTAT's order. Thus, the appeal was dismissed.
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