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 held that the mid-year review and revision of Tariff Rate Quota (TRQ) allocations conducted by the Respondents without affording an opportunity of hearing and sufficient prior notice to the Petitioners lacked specified criteria and was procedurally flawed. The Court directed the Directorate General of Foreign Trade (DGFT) to examine the issues raised by the Petitioners and issue a fresh decision based on the review within three weeks, maintaining the current allocations until then. The petitions were disposed of.
The High Court held that the mid-year review and revision of Tariff Rate Quota (TRQ) allocations conducted by the Respondents without affording an opportunity of hearing and sufficient prior notice to the Petitioners lacked specified criteria and was procedurally flawed. The Court directed the Directorate General of Foreign Trade (DGFT) to examine the issues raised by the Petitioners and issue a fresh decision based on the review within three weeks, maintaining the current allocations until then. The petitions were disposed of.
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