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...
CESTAT New Delhi held that an aircraft used for transporting persons for remuneration falls under public transport, not private use. Referring to M/s.V.R.L. Logistics, it determined the aircraft's usage as non-scheduled (Passenger) service, complying with Condition No.104 of Notification No.21/2002-Cus. The Tribunal upheld the decision, dismissing appeals as no violation occurred, resolving issues of confiscation, interest, and penalty. The definition of 'Air Transport Service' and 'Scheduled Air Transport Service' from Aircraft Rules guided the classification, emphasizing the distinction between private and public transport aircraft.
CESTAT New Delhi held that an aircraft used for transporting persons for remuneration falls under public transport, not private use. Referring to M/s.V.R.L. Logistics, it determined the aircraft's usage as non-scheduled (Passenger) service, complying with Condition No.104 of Notification No.21/2002-Cus. The Tribunal upheld the decision, dismissing appeals as no violation occurred, resolving issues of confiscation, interest, and penalty. The definition of 'Air Transport Service' and 'Scheduled Air Transport Service' from Aircraft Rules guided the classification, emphasizing the distinction between private and public transport aircraft.
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