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 Act, 1962 - Penalty levied on appellant as co-noticee for principal violator's diversion of duty-free imported goods under DEEC scheme to local market without fulfilling export obligation. Appellant's relationship with principal violator not sufficient evidence of knowledge about modus operandi. Appellant severed ties with partnership firm after payment issue. Commissioner's order imposing penalty set aside by Appellate Tribunal due to lack of corroborative evidence against appellant.
Customs Act, 1962 - Penalty levied on appellant as co-noticee for principal violator's diversion of duty-free imported goods under DEEC scheme to local market without fulfilling export obligation. Appellant's relationship with principal violator not sufficient evidence of knowledge about modus operandi. Appellant severed ties with partnership firm after payment issue. Commissioner's order imposing penalty set aside by Appellate Tribunal due to lack of corroborative evidence against appellant.
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