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 failed to submit original shipping bills to substantiate claimed exports, providing only photocopies which were not accepted for meeting export obligation. Two shipping bills fell outside extended export obligation period, two were Drawback Shipping Bills with rejected conversion requests. Petitioner claimed loss of Duty Exemption Entitlement Certificate Book but provided unsatisfactory explanation before Appellate and Reviewing Authorities. Petitioner did not submit required documents to demonstrate compliance with export obligation and failed to appear for personal hearings despite opportunities. Petitioner did not provide written response to objections raised. Petitioner failed to prove Customs Authority's agreement to convert Drawback Shipping Bills to DEEC Shipping Bills and did not submit documents proving export obligation fulfilment or pay prescribed customs duty. Orders rejecting review petition found reasonable based on facts, not arbitrary. High Court dismissed petition, finding no grounds for interference under Article 226 of Constitution of India, 1950.
Petitioner failed to submit original shipping bills to substantiate claimed exports, providing only photocopies which were not accepted for meeting export obligation. Two shipping bills fell outside extended export obligation period, two were Drawback Shipping Bills with rejected conversion requests. Petitioner claimed loss of Duty Exemption Entitlement Certificate Book but provided unsatisfactory explanation before Appellate and Reviewing Authorities. Petitioner did not submit required documents to demonstrate compliance with export obligation and failed to appear for personal hearings despite opportunities. Petitioner did not provide written response to objections raised. Petitioner failed to prove Customs Authority's agreement to convert Drawback Shipping Bills to DEEC Shipping Bills and did not submit documents proving export obligation fulfilment or pay prescribed customs duty. Orders rejecting review petition found reasonable based on facts, not arbitrary. High Court dismissed petition, finding no grounds for interference under Article 226 of Constitution of India, 1950.
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