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 involves a Customs Broker's license revocation for involvement in mis-declaration and fraudulent export of "Uric Acid." The Commissioner of Customs followed the prescribed timeline u/s Regulation 20 of CBLR, 2013 for issuing Show Cause Notice, conducting inquiry, and issuing the Order-in-Original. The revocation proceedings were found not time-barred. The Broker's license was misused for financial gain in fraudulent transactions, leading to fine and forfeiture of security deposit. The Tribunal modified the order, setting aside license revocation but upholding the penalty and forfeiture.
The case involves a Customs Broker's license revocation for involvement in mis-declaration and fraudulent export of "Uric Acid." The Commissioner of Customs followed the prescribed timeline u/s Regulation 20 of CBLR, 2013 for issuing Show Cause Notice, conducting inquiry, and issuing the Order-in-Original. The revocation proceedings were found not time-barred. The Broker's license was misused for financial gain in fraudulent transactions, leading to fine and forfeiture of security deposit. The Tribunal modified the order, setting aside license revocation but upholding the penalty and forfeiture.
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