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...
Classification of goods - rate of tax - Classic Malabar Parota - Whole Wheat Malabar Parota - The court determined that the Malabar Parotas should not be classified under the heading 2106 as they are not akin to the other food preparations specified therein, which typically include items requiring more substantial processing. - The court highlighted that the 'bread' definition in the GST regime should be broadly interpreted to include varieties of bread prevalent in different cultures, including Indian flatbreads. - Ultimately, the court held that since Malabar Parotas are akin to items specified under tariff item 1905 9090, they should attract a GST of 5% (2.5% CGST + 2.5% SGST), as they are similar to products like Khakhra, plain chapati, or roti, which are also covered under this entry.
Classification of goods - rate of tax - Classic Malabar Parota - Whole Wheat Malabar Parota - The court determined that the Malabar Parotas should not be classified under the heading 2106 as they are not akin to the other food preparations specified therein, which typically include items requiring more substantial processing. - The court highlighted that the 'bread' definition in the GST regime should be broadly interpreted to include varieties of bread prevalent in different cultures, including Indian flatbreads. - Ultimately, the court held that since Malabar Parotas are akin to items specified under tariff item 1905 9090, they should attract a GST of 5% (2.5% CGST + 2.5% SGST), as they are similar to products like Khakhra, plain chapati, or roti, which are also covered under this entry.
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