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...
Re-export of even after the expiry of the warehousing period - Due to COVID-19 pandemic, the appellants were unable to proceed with their construction project and clear the goods for home consumption - In light of the circumstances, including the COVID-19 pandemic and the appellant's efforts to re-export the goods, the Tribunal found merit in the appellant's arguments. They emphasized the need for flexibility in such exceptional situations and cited the judgement of the Hon’ble Supreme Court regarding the extension of limitation period. Consequently, the Tribunal set aside the impugned order and directed the respondent to allow re-export of the goods within a specified period without insisting on payment of duty, interest, fine, or penalty.
Re-export of even after the expiry of the warehousing period - Due to COVID-19 pandemic, the appellants were unable to proceed with their construction project and clear the goods for home consumption - In light of the circumstances, including the COVID-19 pandemic and the appellant's efforts to re-export the goods, the Tribunal found merit in the appellant's arguments. They emphasized the need for flexibility in such exceptional situations and cited the judgement of the Hon’ble Supreme Court regarding the extension of limitation period. Consequently, the Tribunal set aside the impugned order and directed the respondent to allow re-export of the goods within a specified period without insisting on payment of duty, interest, fine, or penalty.
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