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...
Imported material diverted to unit other than permitted unit, resulting in contravention of import-export policy provisions. Goods held liable for confiscation u/s 111 and importer penalized u/s 112 of Customs Act. Appellant claimed permission for Wada unit valid for Panipat unit, refuted by Ministry's clarification. Confiscation and penalty upheld, but redemption fine reduced to Rs.3 lakhs and penalty to Rs.2 lakhs considering total value of Rs.22 lakhs. Appellate Tribunal's order regarding diversion of imported goods to unauthorized unit and consequent penalties.
Imported material diverted to unit other than permitted unit, resulting in contravention of import-export policy provisions. Goods held liable for confiscation u/s 111 and importer penalized u/s 112 of Customs Act. Appellant claimed permission for Wada unit valid for Panipat unit, refuted by Ministry's clarification. Confiscation and penalty upheld, but redemption fine reduced to Rs.3 lakhs and penalty to Rs.2 lakhs considering total value of Rs.22 lakhs. Appellate Tribunal's order regarding diversion of imported goods to unauthorized unit and consequent penalties.
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