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...
Customs valuation of imported cyanuric chloride - revenue rejected declared value based on NIDB and contemporaneous import data showing higher prices for smaller quantities - appellant imported 2000 MT at lower negotiated price - CESTAT held quantity imported significantly different from NIDB data relied upon by revenue, hence cannot be compared - no other evidence cited by authorities - orders set aside, appeal allowed.
Customs valuation of imported cyanuric chloride - revenue rejected declared value based on NIDB and contemporaneous import data showing higher prices for smaller quantities - appellant imported 2000 MT at lower negotiated price - CESTAT held quantity imported significantly different from NIDB data relied upon by revenue, hence cannot be compared - no other evidence cited by authorities - orders set aside, appeal allowed.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4796
Join Channel
TaxTMI 
