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 High Court upheld the penalty imposed u/s 112(a) of the Customs Act, 1962 on the Appellant. The Court found the order cryptic and non-speaking, violating principles of natural justice. The CESTAT and Commissioner concluded that the appellants were abettors in a fraud scheme involving Ascorbic Acid. The Commissioner determined that the Managing Director played an active role in the fraud, resulting in substantial loss to Government Revenue. The CESTAT confirmed these findings, stating no substantial question of law arises. The appeal was dismissed, affirming the abetment of duty evasion.
The High Court upheld the penalty imposed u/s 112(a) of the Customs Act, 1962 on the Appellant. The Court found the order cryptic and non-speaking, violating principles of natural justice. The CESTAT and Commissioner concluded that the appellants were abettors in a fraud scheme involving Ascorbic Acid. The Commissioner determined that the Managing Director played an active role in the fraud, resulting in substantial loss to Government Revenue. The CESTAT confirmed these findings, stating no substantial question of law arises. The appeal was dismissed, affirming the abetment of duty evasion.
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