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 allowed the petition and held that the petitioner is entitled to exemption from payment of excise duty up to 1% on transit loss for petroleum products transferred from the refinery/factory to the place of storage for the purpose of export. The impugned orders passed by the revisional authority were set aside, and the order passed by the Commissioner (Appeals) was restored. The demand raised regarding duty, interest, and penalty was quashed.
The High Court allowed the petition and held that the petitioner is entitled to exemption from payment of excise duty up to 1% on transit loss for petroleum products transferred from the refinery/factory to the place of storage for the purpose of export. The impugned orders passed by the revisional authority were set aside, and the order passed by the Commissioner (Appeals) was restored. The demand raised regarding duty, interest, and penalty was quashed.
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