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 of export goods - Iron Ore Fines - transaction value - FOB price - Export duty - The appellant contested this, arguing that unless the Revenue disputes the transaction value with corroborative evidence, it should be considered valid, citing relevant case laws. The Tribunal concurred, emphasizing that the Revenue had not doubted the transaction value and had not followed sequential valuation rules before adopting contemporaneous values. As the Revenue did not contest the Adjudicating Authority's findings, the transaction value's correctness was upheld, and the appeal was allowed.
Valuation of export goods - Iron Ore Fines - transaction value - FOB price - Export duty - The appellant contested this, arguing that unless the Revenue disputes the transaction value with corroborative evidence, it should be considered valid, citing relevant case laws. The Tribunal concurred, emphasizing that the Revenue had not doubted the transaction value and had not followed sequential valuation rules before adopting contemporaneous values. As the Revenue did not contest the Adjudicating Authority's findings, the transaction value's correctness was upheld, and the appeal was allowed.
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