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...
Right of the Purchaser of confiscated vessel in an action - Direction to issue No Due Certificate (NDC) in relation to subject vessel MSV Safina Al-Miraz to the Petitioner and permit the Petitioner to shift the Vessel from Salaya Port to Okha Port forthwith - The High Court referred to Sections 115 and 126 of the Customs Act, stating that upon confiscation, the confiscated goods vested in the Central Government. Consequently, any encumbrances, including the mortgage by the GMB, would cease to exist. - Given the legal framework and absence of outstanding dues, the Court directed the GMB to issue the NDC to the petitioner, enabling them to shift the vessel. The rule was made absolute in this regard, with no orders as to costs.
Right of the Purchaser of confiscated vessel in an action - Direction to issue No Due Certificate (NDC) in relation to subject vessel MSV Safina Al-Miraz to the Petitioner and permit the Petitioner to shift the Vessel from Salaya Port to Okha Port forthwith - The High Court referred to Sections 115 and 126 of the Customs Act, stating that upon confiscation, the confiscated goods vested in the Central Government. Consequently, any encumbrances, including the mortgage by the GMB, would cease to exist. - Given the legal framework and absence of outstanding dues, the Court directed the GMB to issue the NDC to the petitioner, enabling them to shift the vessel. The rule was made absolute in this regard, with no orders as to costs.
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