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 Competition Commission of India (CCI) examined whether Indian Rare Earths Limited (IREL), a public sector undertaking, contravened Section 4 of the Competition Act, 2002, by abusing its dominant position in the market for mining and supply of Beach Sand Sillimanite in India. CCI held that IREL is an 'enterprise' under the Act and the relevant geographic market is India. Despite IREL's high market share, CCI found no evidence of excessive or discriminatory pricing by IREL in violation of Sections 4(2)(a)(ii) and 4(2)(a)(i) respectively. CCI observed that differential pricing based on quantity, customer relationships, and assured offtake is a normal business practice. Consequently, CCI concluded that IREL did not contravene the provisions of Section 4 and directed the matter to be closed, while addressing confidentiality requests from parties.
The Competition Commission of India (CCI) examined whether Indian Rare Earths Limited (IREL), a public sector undertaking, contravened Section 4 of the Competition Act, 2002, by abusing its dominant position in the market for mining and supply of Beach Sand Sillimanite in India. CCI held that IREL is an 'enterprise' under the Act and the relevant geographic market is India. Despite IREL's high market share, CCI found no evidence of excessive or discriminatory pricing by IREL in violation of Sections 4(2)(a)(ii) and 4(2)(a)(i) respectively. CCI observed that differential pricing based on quantity, customer relationships, and assured offtake is a normal business practice. Consequently, CCI concluded that IREL did not contravene the provisions of Section 4 and directed the matter to be closed, while addressing confidentiality requests from parties.
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