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...
Smuggling - Gold - baggage rules - The petitioners, a husband and wife, returned to India from the United States and were stopped by customs officials upon arrival. The officials found the wife wearing five gold bangles, which had not been declared. The petitioners claimed the bangles were a gift from their daughter. - The High court categorized the gold bangles as restricted items under customs laws, emphasizing that failure to declare such items amounts to their prohibition. - The court found that the petitioners' failure to declare the gold bangles constituted a violation of customs laws, as they exceeded the permissible limits for duty-free importation. - The court upheld the adjudicating authority's decision to confiscate the gold bangles and impose fines and duties, citing the provisions of the Customs Act and related regulations.
Smuggling - Gold - baggage rules - The petitioners, a husband and wife, returned to India from the United States and were stopped by customs officials upon arrival. The officials found the wife wearing five gold bangles, which had not been declared. The petitioners claimed the bangles were a gift from their daughter. - The High court categorized the gold bangles as restricted items under customs laws, emphasizing that failure to declare such items amounts to their prohibition. - The court found that the petitioners' failure to declare the gold bangles constituted a violation of customs laws, as they exceeded the permissible limits for duty-free importation. - The court upheld the adjudicating authority's decision to confiscate the gold bangles and impose fines and duties, citing the provisions of the Customs Act and related regulations.
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