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...
Mangala Borosan and Mangala G1 are not classifiable under Chapter Heading 3105 as Fertilisers as they lack essential fertilizing elements like Nitrogen, Phosphorus, or Potassium as stipulated by Chapter Notes. Classification is determined by product description, inclusion/exclusion in Section/Chapter Notes, and General Rules of Interpretation, not claimed usage or results. Appellant's contention of Nitrogen emanation during usage is untenable as products are assessed based on form and contents at presentation/supply. Definition of "Fertiliser" under relevant law requires essential plant nutrients like Nitrogen, Phosphorous, and Potassium, irrespective of State Government's notification of micronutrients. AAAR upheld classification outside Chapter 31.
Mangala Borosan and Mangala G1 are not classifiable under Chapter Heading 3105 as Fertilisers as they lack essential fertilizing elements like Nitrogen, Phosphorus, or Potassium as stipulated by Chapter Notes. Classification is determined by product description, inclusion/exclusion in Section/Chapter Notes, and General Rules of Interpretation, not claimed usage or results. Appellant's contention of Nitrogen emanation during usage is untenable as products are assessed based on form and contents at presentation/supply. Definition of "Fertiliser" under relevant law requires essential plant nutrients like Nitrogen, Phosphorous, and Potassium, irrespective of State Government's notification of micronutrients. AAAR upheld classification outside Chapter 31.
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