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...
Recovery of duty drawback granted earlier with interest - The petitioner claimed non-receipt of the show cause notice and argued that the sale proceeds had been realized, citing the availability of the Bank Realization Certificate online. However, the petitioner did not produce the certificate during the enquiry, leading to the issuance of the impugned order. The High Court, while acknowledging the petitioner's arguments, emphasized the importance of producing relevant documents during the enquiry process. Consequently, the Court remanded the matter back to the authorities.
Recovery of duty drawback granted earlier with interest - The petitioner claimed non-receipt of the show cause notice and argued that the sale proceeds had been realized, citing the availability of the Bank Realization Certificate online. However, the petitioner did not produce the certificate during the enquiry, leading to the issuance of the impugned order. The High Court, while acknowledging the petitioner's arguments, emphasized the importance of producing relevant documents during the enquiry process. Consequently, the Court remanded the matter back to the authorities.
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