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 High Court expressed concerns over the Revenue's representative's contradictory statements regarding the availability of test reports issued by IRMRA during the main appeal hearing and the subsequent rectification application hearing before the Tribunal. The Court directed the Joint Chief Department Representative, Mumbai Bench CESTAT, to conduct a detailed inquiry into how such an incident occurred, identify the responsible individuals, and report to the Court on the disciplinary actions taken or proposed against those from the Revenue Department, as well as any actions against private individuals involved. The Court emphasized the seriousness of the matter, considering the high financial stakes and the series of appellants before the Tribunal.
The High Court expressed concerns over the Revenue's representative's contradictory statements regarding the availability of test reports issued by IRMRA during the main appeal hearing and the subsequent rectification application hearing before the Tribunal. The Court directed the Joint Chief Department Representative, Mumbai Bench CESTAT, to conduct a detailed inquiry into how such an incident occurred, identify the responsible individuals, and report to the Court on the disciplinary actions taken or proposed against those from the Revenue Department, as well as any actions against private individuals involved. The Court emphasized the seriousness of the matter, considering the high financial stakes and the series of appellants before the Tribunal.
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