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...
Benefit of Nil Rate of duty - MS Pipes - Notification No.6/2002 - The Tribunal observed that the appellant failed to produce certificates from the District Collector for some clearances, leading to confirmation of duty along with interest. However, where certificates were produced, the Tribunal held that the benefit of the exemption should not be denied solely based on format discrepancies in the certificates. The Tribunal emphasized that the essence of the certificates aligned with the purpose outlined in the notification, warranting the appellant's eligibility for the Nil rate of duty.
Benefit of Nil Rate of duty - MS Pipes - Notification No.6/2002 - The Tribunal observed that the appellant failed to produce certificates from the District Collector for some clearances, leading to confirmation of duty along with interest. However, where certificates were produced, the Tribunal held that the benefit of the exemption should not be denied solely based on format discrepancies in the certificates. The Tribunal emphasized that the essence of the certificates aligned with the purpose outlined in the notification, warranting the appellant's eligibility for the Nil rate of duty.
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