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 - it is alleged that respondents have shown excess manufacture in order to avail excess refund to the tune of Rs. 60 lakhs - burden of proof lies with the prosecution or not - The Tribunal acknowledges the serious nature of the charge but finds that the Revenue failed to establish tangible evidence beyond a single test run. They emphasize the necessity of thorough investigation and tangible evidence to prove such allegations conclusively. - The Tribunal notes the various factors affecting fuel consumption and production, concluding that a single test run cannot accurately represent overall production.
Clandestine removal - it is alleged that respondents have shown excess manufacture in order to avail excess refund to the tune of Rs. 60 lakhs - burden of proof lies with the prosecution or not - The Tribunal acknowledges the serious nature of the charge but finds that the Revenue failed to establish tangible evidence beyond a single test run. They emphasize the necessity of thorough investigation and tangible evidence to prove such allegations conclusively. - The Tribunal notes the various factors affecting fuel consumption and production, concluding that a single test run cannot accurately represent overall production.
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