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...
Appellants challenged confiscation of containers, imposition of redemption fine, and penalty due to inordinate delay in adjudication. Tribunal found procedural lapse by appellants but acknowledged delay caused by department's hold on containers. 231 out of 236 containers exported before show cause notice. Tribunal ruled confiscation, redemption fine, and penalty on exported containers incorrect. However, duty payable on remaining 5 unexported containers and penalty of Rs. 50,000 u/s 112 of Customs Act imposed for infractions. Appeal partly allowed, confiscation and redemption fine on exported containers set aside.
Appellants challenged confiscation of containers, imposition of redemption fine, and penalty due to inordinate delay in adjudication. Tribunal found procedural lapse by appellants but acknowledged delay caused by department's hold on containers. 231 out of 236 containers exported before show cause notice. Tribunal ruled confiscation, redemption fine, and penalty on exported containers incorrect. However, duty payable on remaining 5 unexported containers and penalty of Rs. 50,000 u/s 112 of Customs Act imposed for infractions. Appeal partly allowed, confiscation and redemption fine on exported containers set aside.
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