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 safeguard duty - Determination of effective date and time of implementation of Notification - The appellant argued that the notification was only effective from its publication date in the Official Gazette, which was 24.02.2013. The Tribunal considered various judicial precedents and concluded that a notification becomes effective only upon its publication in the Official Gazette. Since the appellant’s goods were imported before the publication date, the safeguard duty could not be imposed.
Levy of safeguard duty - Determination of effective date and time of implementation of Notification - The appellant argued that the notification was only effective from its publication date in the Official Gazette, which was 24.02.2013. The Tribunal considered various judicial precedents and concluded that a notification becomes effective only upon its publication in the Official Gazette. Since the appellant’s goods were imported before the publication date, the safeguard duty could not be imposed.
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