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...
Validity of order of CESTAT - Redemption for home consumption allowed, despite admitting the fact that the condition of para 2.31 of the Foreign Trade Policy are not satisfied - Scope of the CRO, 2012, which covers Multifunctional and Printers/ Devices (MFDs) along with printers and plotters - The High Court dismissed the appeal, citing a previous judgment addressing similar issues. The Court noted that the goods in question had already been released on payment of duty and other dues. Consequently, the High Court upheld the Tribunal's decision while leaving the substantial questions of law open for future adjudication.
Validity of order of CESTAT - Redemption for home consumption allowed, despite admitting the fact that the condition of para 2.31 of the Foreign Trade Policy are not satisfied - Scope of the CRO, 2012, which covers Multifunctional and Printers/ Devices (MFDs) along with printers and plotters - The High Court dismissed the appeal, citing a previous judgment addressing similar issues. The Court noted that the goods in question had already been released on payment of duty and other dues. Consequently, the High Court upheld the Tribunal's decision while leaving the substantial questions of law open for future adjudication.
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