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...
Revocation of Licenced Customs Broker Licence - The Commissioner alleged violations of various provisions of the CBLR, particularly related to bribery. However, the appellant contested these allegations, arguing that the amounts in question were for legitimate expenses, not bribes, and that they cannot be held responsible for the actions of their employees without evidence of authorization. The Tribunal found that the allegations were based on preliminary findings and lacked sufficient evidence to substantiate them. Therefore, it set aside the Commissioner's order, ruling that the proceedings were premature and unsubstantiated. - Therefore, the Tribunal set aside the Commissioner's order.
Revocation of Licenced Customs Broker Licence - The Commissioner alleged violations of various provisions of the CBLR, particularly related to bribery. However, the appellant contested these allegations, arguing that the amounts in question were for legitimate expenses, not bribes, and that they cannot be held responsible for the actions of their employees without evidence of authorization. The Tribunal found that the allegations were based on preliminary findings and lacked sufficient evidence to substantiate them. Therefore, it set aside the Commissioner's order, ruling that the proceedings were premature and unsubstantiated. - Therefore, the Tribunal set aside the Commissioner's order.
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