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 - Inclusion of lump sum and periodical patent and technology know how fee paid - The Tribunal analyzed the provisions of Rule 10 (1) (c) of the Customs Valuation (Determination of Value of Imported Goods) Rules, 2007, and relevant case laws. It was concluded that the royalty and technical know-how fees were not a condition of the sale of the imported goods. Thus, these fees should not be included in the transaction value. The court emphasized the distinction between costs related to the import of goods and those pertaining to post-importation manufacturing activities.
Valuation of imported goods - Inclusion of lump sum and periodical patent and technology know how fee paid - The Tribunal analyzed the provisions of Rule 10 (1) (c) of the Customs Valuation (Determination of Value of Imported Goods) Rules, 2007, and relevant case laws. It was concluded that the royalty and technical know-how fees were not a condition of the sale of the imported goods. Thus, these fees should not be included in the transaction value. The court emphasized the distinction between costs related to the import of goods and those pertaining to post-importation manufacturing activities.
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