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 imported goods - Applicable rate of IGST - 28% or 18% - Scope of the term "i.e."- Interpretation of the Notification No.1/2017-IGST-Rate - Import of branded nutrition/ dietary supplements - Regarding the classification of goods, it determined that the appellant's goods did not fall under the specific items listed under Entry No. 9 of Schedule IV. Instead, they were found to be covered under Entry No. 453 of Schedule III, as they were not specified in any other schedule. - In relation to the interpretation of the Schedule IV entry, the Tribunal reiterated that the use of "i.e." in the entry limited its scope to the items listed thereafter, excluding any other products not explicitly mentioned.
Classification of imported goods - Applicable rate of IGST - 28% or 18% - Scope of the term "i.e."- Interpretation of the Notification No.1/2017-IGST-Rate - Import of branded nutrition/ dietary supplements - Regarding the classification of goods, it determined that the appellant's goods did not fall under the specific items listed under Entry No. 9 of Schedule IV. Instead, they were found to be covered under Entry No. 453 of Schedule III, as they were not specified in any other schedule. - In relation to the interpretation of the Schedule IV entry, the Tribunal reiterated that the use of "i.e." in the entry limited its scope to the items listed thereafter, excluding any other products not explicitly mentioned.
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