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...
Seeking to recover the refund of SAD already sanctioned - imported timber log and paid SAD - The Tribunal upheld the appellant's contention that they were entitled to the refund despite selling cut and sawn timber logs. Citing legal precedents and the purpose of the exemption notification, the Tribunal ruled that the conversion of logs did not disqualify the appellant from the refund. - The Tribunal agreed with the appellant that as they were not registered dealers, the requirement for endorsement on invoices did not apply to them.
Seeking to recover the refund of SAD already sanctioned - imported timber log and paid SAD - The Tribunal upheld the appellant's contention that they were entitled to the refund despite selling cut and sawn timber logs. Citing legal precedents and the purpose of the exemption notification, the Tribunal ruled that the conversion of logs did not disqualify the appellant from the refund. - The Tribunal agreed with the appellant that as they were not registered dealers, the requirement for endorsement on invoices did not apply to them.
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