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...
Valuation - Export of Carpets and threading bars - Mis-declaration of description and value - The Tribunal found that while the carpets were misdeclared and subject to confiscation, the threading bars were not misdeclared. The redetermined value was set aside due to lack of evidence from the department to counter procurement documents provided by the respondent. The reduction of redemption fine and penalty was partially upheld considering the admitted misdeclaration by the respondent.
Valuation - Export of Carpets and threading bars - Mis-declaration of description and value - The Tribunal found that while the carpets were misdeclared and subject to confiscation, the threading bars were not misdeclared. The redetermined value was set aside due to lack of evidence from the department to counter procurement documents provided by the respondent. The reduction of redemption fine and penalty was partially upheld considering the admitted misdeclaration by the respondent.
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