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...
Seeking amendment of shipping bills - inadvertent error in the Shipping bills - seeking to credit ROSCTL benefit amounts to the petitioner’s Customs E-Scrip Ledger - The High Court noted that the petitioner's intention to claim benefits under the RoSCTL Scheme was evident from the Shipping bills and other related documents, despite the inadvertent error in declaration. Drawing from judgments of the Madras High Court, the High Court concluded that such errors, if inadvertent, should not deprive exporters of entitled benefits.
Seeking amendment of shipping bills - inadvertent error in the Shipping bills - seeking to credit ROSCTL benefit amounts to the petitioner’s Customs E-Scrip Ledger - The High Court noted that the petitioner's intention to claim benefits under the RoSCTL Scheme was evident from the Shipping bills and other related documents, despite the inadvertent error in declaration. Drawing from judgments of the Madras High Court, the High Court concluded that such errors, if inadvertent, should not deprive exporters of entitled benefits.
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