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...
Coin blanks of copper alloys/strips of copper/coils of zinc & nickel to be classified under CETH 74094000 as copper plates, sheets and strips exceeding 0.15mm thickness of copper nickel base alloys or under 7419. Coin blanks cannot be classified along with plates and strips as they have distinctive shape, size, character and use; plates and strips are raw materials while coin blanks are near-finished manufactured items. Copper strips and coin blanks constitute similar goods to avail benefit under Para 6.8(a) of Foreign Trade Policy, 2009-14. Education Cess cannot be charged twice after being added to Customs duties. No penalty can be imposed u/r 25 of Central Excise Rules as the issue pertains to legal interpretation, and advance rulings favored the appellants on classification. Appeal allowed in part.
Coin blanks of copper alloys/strips of copper/coils of zinc & nickel to be classified under CETH 74094000 as copper plates, sheets and strips exceeding 0.15mm thickness of copper nickel base alloys or under 7419. Coin blanks cannot be classified along with plates and strips as they have distinctive shape, size, character and use; plates and strips are raw materials while coin blanks are near-finished manufactured items. Copper strips and coin blanks constitute similar goods to avail benefit under Para 6.8(a) of Foreign Trade Policy, 2009-14. Education Cess cannot be charged twice after being added to Customs duties. No penalty can be imposed u/r 25 of Central Excise Rules as the issue pertains to legal interpretation, and advance rulings favored the appellants on classification. Appeal allowed in part.
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