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...
Violation of Regulation 10(d) of CBLR established - appellant obligated to advise client about authorization requirement for SCOMET item export, instead filed Shipping Bill. Appellant's reliance on client's declaration unacceptable - onus on appellant to know law. SCN not time-barred - issued within 80 days of receipt of correct offence report. Revocation of license, forfeiture of security deposit disproportionate considering no evidence of profiting, appellant out of work for a year. Penalty of Rs. 50,000/- upheld, revocation and forfeiture set aside. Appeal partly allowed.
Violation of Regulation 10(d) of CBLR established - appellant obligated to advise client about authorization requirement for SCOMET item export, instead filed Shipping Bill. Appellant's reliance on client's declaration unacceptable - onus on appellant to know law. SCN not time-barred - issued within 80 days of receipt of correct offence report. Revocation of license, forfeiture of security deposit disproportionate considering no evidence of profiting, appellant out of work for a year. Penalty of Rs. 50,000/- upheld, revocation and forfeiture set aside. Appeal partly allowed.
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