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...
The petitioner's products were previously classified under heading 7615 of the Customs Tariff Act, 1975, but the Department contended that some products should be classified under heading 7607. The High Court had earlier allowed the petitioner's writ petitions challenging a similar order, following the Supreme Court's order in Commissioner of Central Excise vs. Hindalco Industries Limited, holding that the Aluminium Foil Container is classifiable under 7615 with 12% GST. Consequently, the High Court allowed the present writ petitions and directed the refund of the pre-deposited amount by the petitioner within 30 days, as the order was accepted by the Commissioner GST Central Excise, Madurai.
The petitioner's products were previously classified under heading 7615 of the Customs Tariff Act, 1975, but the Department contended that some products should be classified under heading 7607. The High Court had earlier allowed the petitioner's writ petitions challenging a similar order, following the Supreme Court's order in Commissioner of Central Excise vs. Hindalco Industries Limited, holding that the Aluminium Foil Container is classifiable under 7615 with 12% GST. Consequently, the High Court allowed the present writ petitions and directed the refund of the pre-deposited amount by the petitioner within 30 days, as the order was accepted by the Commissioner GST Central Excise, Madurai.
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