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...
Appellate Tribunal set aside orders denying remission of excise duty on indigenous goods and customs duty on imported goods destroyed in factory fire. Tribunal found no dispute regarding fire incident and destruction of goods, appellant received insurance claim, no evidence of mischief or carelessness by appellant. Commissioner raised deficiencies in remission application without giving appellant opportunity to explain. Matter remanded to Commissioner for reconsideration of remission application after giving proper opportunity to appellant to address queries raised. Consequential demands of duty also set aside for fresh adjudication along with remission application by competent authority.
Appellate Tribunal set aside orders denying remission of excise duty on indigenous goods and customs duty on imported goods destroyed in factory fire. Tribunal found no dispute regarding fire incident and destruction of goods, appellant received insurance claim, no evidence of mischief or carelessness by appellant. Commissioner raised deficiencies in remission application without giving appellant opportunity to explain. Matter remanded to Commissioner for reconsideration of remission application after giving proper opportunity to appellant to address queries raised. Consequential demands of duty also set aside for fresh adjudication along with remission application by competent authority.
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