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...
Petitioner sought implementation of Appellate Authority's order to release seized gold ornaments due to discrepancy between delivery challan quantity and actual quantity. Court held that although goods are liable for confiscation, they can be released upon payment of fine considering they are petitioner's stock-in-trade. Petitions disposed, directing release of entire 1647.970 grams of seized gold to petitioners upon executing bonds, undertaking not to alienate covered property until proceedings culminate. Parties entitled to approach Appellate Tribunal if aggrieved by Appellate Authority's proceedings.
Petitioner sought implementation of Appellate Authority's order to release seized gold ornaments due to discrepancy between delivery challan quantity and actual quantity. Court held that although goods are liable for confiscation, they can be released upon payment of fine considering they are petitioner's stock-in-trade. Petitions disposed, directing release of entire 1647.970 grams of seized gold to petitioners upon executing bonds, undertaking not to alienate covered property until proceedings culminate. Parties entitled to approach Appellate Tribunal if aggrieved by Appellate Authority's proceedings.
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