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...
Duty Drawback claim denied due to clarificatory Circular No.55/99-Cus retrospectively applicable. Petitioner's exported product, Woolen Readymade Garments, excluded from S.S.NO.62.09 covering only woollen Suits/Trousers/Blazers/Jackets as per Circular. Revisional Authority's order upheld, relying on Karnataka High Court decision in CCE Bangalore Vs. Central Manufacturing Technology Institute, clarifying retrospective nature of clarificatory notifications. Petitioner entitled only to Brand Rate, not Drawback claim for exported garments other than specified categories. Writ Petition dismissed.
Duty Drawback claim denied due to clarificatory Circular No.55/99-Cus retrospectively applicable. Petitioner's exported product, Woolen Readymade Garments, excluded from S.S.NO.62.09 covering only woollen Suits/Trousers/Blazers/Jackets as per Circular. Revisional Authority's order upheld, relying on Karnataka High Court decision in CCE Bangalore Vs. Central Manufacturing Technology Institute, clarifying retrospective nature of clarificatory notifications. Petitioner entitled only to Brand Rate, not Drawback claim for exported garments other than specified categories. Writ Petition dismissed.
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