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...
Failure to re-export the goods after re-import - Recovery of Drawback - The Appellate Tribunal found that the appellant intended to re-export the goods after repair but could not fulfill this requirement and sold the goods locally instead. Considering similar precedent and a Supreme Court judgment, the Tribunal held that the appellant was indeed eligible for the benefit of Notification No.94/96. However, it was made clear that the appellant must repay the drawback claimed along with interest.
Failure to re-export the goods after re-import - Recovery of Drawback - The Appellate Tribunal found that the appellant intended to re-export the goods after repair but could not fulfill this requirement and sold the goods locally instead. Considering similar precedent and a Supreme Court judgment, the Tribunal held that the appellant was indeed eligible for the benefit of Notification No.94/96. However, it was made clear that the appellant must repay the drawback claimed along with interest.
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