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...
Levy of imposed u/s 114A - Classification of imported goods - import of Shell Flavex Oil 595 B/H - item being Plasticizer - The Appellate Tribunal recognized the bona fide belief of the appellant in classifying the imported goods under CTH 38122090 as plasticizer, given that the tariff entry included the compound "Plasticizer." Furthermore, it noted that this classification was consistent across all Indian ports and was also accepted by the department. The appellant had not contested the duty liability and had paid the entire amount along with interest before the issuance of the show cause notice. - The Tribunal concluded that the appellant's actions did not meet the criteria for penalty imposition under this section. There was no evidence of suppression of fact, collusion, or willful misstatement on the part of the appellant.
Levy of imposed u/s 114A - Classification of imported goods - import of Shell Flavex Oil 595 B/H - item being Plasticizer - The Appellate Tribunal recognized the bona fide belief of the appellant in classifying the imported goods under CTH 38122090 as plasticizer, given that the tariff entry included the compound "Plasticizer." Furthermore, it noted that this classification was consistent across all Indian ports and was also accepted by the department. The appellant had not contested the duty liability and had paid the entire amount along with interest before the issuance of the show cause notice. - The Tribunal concluded that the appellant's actions did not meet the criteria for penalty imposition under this section. There was no evidence of suppression of fact, collusion, or willful misstatement on the part of the appellant.
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