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...
Adjudication of show cause notice (SCN) after several year - The tribunal noted the history of duty exemption, litigation, and subsequent duty imposition on resin extraction. It highlighted the stay on duty payment due to court orders, the challenge to the duty imposition, and the subsequent liability post-2019 judgment. - The tribunal found that the show cause notices issued during the litigation period were unsustainable, given the stay on duty payment and subsequent release of duty amounts to buyers. It also criticized the delayed adjudication, citing legal precedents for setting aside belated orders and unreasonable delays.
Adjudication of show cause notice (SCN) after several year - The tribunal noted the history of duty exemption, litigation, and subsequent duty imposition on resin extraction. It highlighted the stay on duty payment due to court orders, the challenge to the duty imposition, and the subsequent liability post-2019 judgment. - The tribunal found that the show cause notices issued during the litigation period were unsustainable, given the stay on duty payment and subsequent release of duty amounts to buyers. It also criticized the delayed adjudication, citing legal precedents for setting aside belated orders and unreasonable delays.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4800
Join Channel
TaxTMI 
