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...
EPCG Scheme - Benefit of an EXIM scheme - Non fulfilment of the export obligations - The High Court examined the clauses of the bonds executed by the appellant and concluded that the penalty clause in the indemnity cum guarantee bond was valid. This clause mandated payment of 24% interest per annum on the duty saved in case of default. The court differentiated between this penalty and the interest claimed by the Customs Department, affirming the appellant's liability for the penalty outlined in the bonds.
EPCG Scheme - Benefit of an EXIM scheme - Non fulfilment of the export obligations - The High Court examined the clauses of the bonds executed by the appellant and concluded that the penalty clause in the indemnity cum guarantee bond was valid. This clause mandated payment of 24% interest per annum on the duty saved in case of default. The court differentiated between this penalty and the interest claimed by the Customs Department, affirming the appellant's liability for the penalty outlined in the bonds.
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