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 fusible interlining fabric of cotton is not correctly classifiable under Heading 5903 of Chapter 59 of the Customs Tariff Act, 1975. The Heading 5903 applies only to fabrics where impregnation, coating, or covering cannot be seen with the naked eye. The fabric manufactured by the petitioner is partially coated, and the plastic coated pattern is visible on one side. As per the Atira's test report and Chapter Note 2(a)(4) of Chapter 59, such partially covered fabrics fall under Chapters 50 to 55, 58, or 60, not Chapter 59 Heading 5903. The impugned order classifying the product under Heading 5903 is quashed, and the petition is allowed, classifying the product under Chapters 50 to 55, 58, or 60 of the GST Tariff.
The fusible interlining fabric of cotton is not correctly classifiable under Heading 5903 of Chapter 59 of the Customs Tariff Act, 1975. The Heading 5903 applies only to fabrics where impregnation, coating, or covering cannot be seen with the naked eye. The fabric manufactured by the petitioner is partially coated, and the plastic coated pattern is visible on one side. As per the Atira's test report and Chapter Note 2(a)(4) of Chapter 59, such partially covered fabrics fall under Chapters 50 to 55, 58, or 60, not Chapter 59 Heading 5903. The impugned order classifying the product under Heading 5903 is quashed, and the petition is allowed, classifying the product under Chapters 50 to 55, 58, or 60 of the GST Tariff.
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