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 addressed the issue of tax levy and penalty related to the release of a vehicle transporting goods without proper documents beyond the destination. The court rejected the mechanical detention of the consignment based on insufficient grounds provided by the respondent. It also emphasized that undervaluation alone cannot justify the seizure of goods in transit. As no evidence of undervaluation was presented, the appeal of the revenue was deemed meritless and dismissed, with costs made easy for the respondent.
The High Court addressed the issue of tax levy and penalty related to the release of a vehicle transporting goods without proper documents beyond the destination. The court rejected the mechanical detention of the consignment based on insufficient grounds provided by the respondent. It also emphasized that undervaluation alone cannot justify the seizure of goods in transit. As no evidence of undervaluation was presented, the appeal of the revenue was deemed meritless and dismissed, with costs made easy for the respondent.
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