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...
Imports Of Marble slabs - Mis-declaration of quantity in the declared goods - Considering the appellant's failure to contest the discrepancy during assessment and their request for immediate release without a show cause notice, the Tribunal found them legally estopped from challenging the assessment later. - The Tribunal noted the substantial difference between the declared and measured quantities of marble slabs. Despite the appellant's argument regarding technical expertise, the measurements were conducted using standard methods, and the discrepancy was evident. The Tribunal upheld the customs authorities' decision to invoke relevant sections of the Customs Act and impose penalties. - Citing legal precedents, the Tribunal upheld the assessment and penalties imposed by customs authorities.
Imports Of Marble slabs - Mis-declaration of quantity in the declared goods - Considering the appellant's failure to contest the discrepancy during assessment and their request for immediate release without a show cause notice, the Tribunal found them legally estopped from challenging the assessment later. - The Tribunal noted the substantial difference between the declared and measured quantities of marble slabs. Despite the appellant's argument regarding technical expertise, the measurements were conducted using standard methods, and the discrepancy was evident. The Tribunal upheld the customs authorities' decision to invoke relevant sections of the Customs Act and impose penalties. - Citing legal precedents, the Tribunal upheld the assessment and penalties imposed by customs authorities.
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