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...
The case before CESTAT Bangalore involved the levy of National Calamity Contingent Duty (NCCD) on chassis captively consumed in the manufacture of Dumpers. The tribunal held that the chassis did not come into existence at the intermediary stage, as per Chapter Heading and HSN Notes, and therefore, was not dutiable. The question of captive consumption and exemption under N/N. 67/95 did not arise. The impugned order was set aside, and the appeal was allowed. The decision was based on the interpretation of legal provisions and previous rulings in the appellant's favor.
The case before CESTAT Bangalore involved the levy of National Calamity Contingent Duty (NCCD) on chassis captively consumed in the manufacture of Dumpers. The tribunal held that the chassis did not come into existence at the intermediary stage, as per Chapter Heading and HSN Notes, and therefore, was not dutiable. The question of captive consumption and exemption under N/N. 67/95 did not arise. The impugned order was set aside, and the appeal was allowed. The decision was based on the interpretation of legal provisions and previous rulings in the appellant's favor.
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