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...
DFIA scheme - Import of ‘saffron’/ ‘saffron pushali B’ - ‘food flavour’ and ‘food colour’ in edible goods - actual use condition and disclosure - The Tribunal criticized the Customs authority for overstepping its jurisdiction by interpreting the Foreign Trade Policy and the exemptions therein. The Tribunal asserted that the Customs authority's role is limited to tax collection and prohibition enforcement, not policy interpretation. - The Tribunal highlighted that 'actual use' conditions for imports should not extend to post-exportation stages unless explicitly stated.
DFIA scheme - Import of ‘saffron’/ ‘saffron pushali B’ - ‘food flavour’ and ‘food colour’ in edible goods - actual use condition and disclosure - The Tribunal criticized the Customs authority for overstepping its jurisdiction by interpreting the Foreign Trade Policy and the exemptions therein. The Tribunal asserted that the Customs authority's role is limited to tax collection and prohibition enforcement, not policy interpretation. - The Tribunal highlighted that 'actual use' conditions for imports should not extend to post-exportation stages unless explicitly stated.
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