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...
Price parallelism alone cannot establish a cartel u/s 3(3)(a) of the Competition Act, 2002. Evidence of parallel pricing must be supplemented with "plus factors" demonstrating conscious conduct rather than independent business decisions. In the present case, the limited evidence of exchange of calls between sugar mills and the industry association is insufficient to establish a contravention. No case of violation can be made out against any party, and the matters are directed to be closed forthwith. The order does not qualify for confidential treatment u/s 57 of the Act.
Price parallelism alone cannot establish a cartel u/s 3(3)(a) of the Competition Act, 2002. Evidence of parallel pricing must be supplemented with "plus factors" demonstrating conscious conduct rather than independent business decisions. In the present case, the limited evidence of exchange of calls between sugar mills and the industry association is insufficient to establish a contravention. No case of violation can be made out against any party, and the matters are directed to be closed forthwith. The order does not qualify for confidential treatment u/s 57 of the Act.
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