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 was denied benefit under the MEIS Scheme due to an inadvertent mistake where the relevant entry was left blank by the employees of the Customs Broker. The court held that since the respondents had not examined the petitioner's case due to the inadvertent error, it was expedient to direct the respondent to undertake fresh examination of the 16 EDI shipping bills, treating the petitioner's submissions as a 'Yes'. The petitioner and/or authorized representative would be given an opportunity for a personal hearing and to provide relevant documents and clarifications sought by the respondent. The petition was disposed of accordingly.
The petitioner was denied benefit under the MEIS Scheme due to an inadvertent mistake where the relevant entry was left blank by the employees of the Customs Broker. The court held that since the respondents had not examined the petitioner's case due to the inadvertent error, it was expedient to direct the respondent to undertake fresh examination of the 16 EDI shipping bills, treating the petitioner's submissions as a 'Yes'. The petitioner and/or authorized representative would be given an opportunity for a personal hearing and to provide relevant documents and clarifications sought by the respondent. The petition was disposed of accordingly.
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