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...
Circular clarifies issues related to special procedure for manufacturers of specified commodities. Unavailable machine details can be substituted with year of purchase or assigned numeric number. Electricity consumption rating can be certified by Chartered Engineer if unavailable. For goods without MRP, sale price to be reported. Practicing Chartered Engineers from Institute of Engineers India eligible for certification. Procedure not applicable to SEZs, manual packing processes. For multiple machines, details of final packing machine required. In job work, procedure applicable to all involved, including unregistered job workers through principal manufacturer.
Circular clarifies issues related to special procedure for manufacturers of specified commodities. Unavailable machine details can be substituted with year of purchase or assigned numeric number. Electricity consumption rating can be certified by Chartered Engineer if unavailable. For goods without MRP, sale price to be reported. Practicing Chartered Engineers from Institute of Engineers India eligible for certification. Procedure not applicable to SEZs, manual packing processes. For multiple machines, details of final packing machine required. In job work, procedure applicable to all involved, including unregistered job workers through principal manufacturer.
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