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...
Misdeclaration of the transaction value - Import of Copper Cathodes - Acceptance of loaded value of the consignments earlier - The tribunal noted that apart from the discrepancy in dates between the invoice and bill of lading, the revenue authority provided no valid reason to reject the declared value. The appellant's explanation regarding the variation in price was considered normal trade practice and was not refuted with evidence or reasoning by the revenue authority. Therefore, the tribunal ruled that the declared value should be accepted. - The tribunal affirmed that past acceptance of loaded values did not bind the appellant to accept the re-assessed value in the current case.
Misdeclaration of the transaction value - Import of Copper Cathodes - Acceptance of loaded value of the consignments earlier - The tribunal noted that apart from the discrepancy in dates between the invoice and bill of lading, the revenue authority provided no valid reason to reject the declared value. The appellant's explanation regarding the variation in price was considered normal trade practice and was not refuted with evidence or reasoning by the revenue authority. Therefore, the tribunal ruled that the declared value should be accepted. - The tribunal affirmed that past acceptance of loaded values did not bind the appellant to accept the re-assessed value in the current case.
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