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 imported goods "Quick Lime" would be properly classifiable under Customs Tariff Item 25221000 and not under Customs Tariff Item 28259090 of the Customs Tariff Act. Quicklime falls under the scope of Chapter 25 covering mineral products like lime and cement, and not under Chapter 28 covering inorganic chemicals. Calcium oxide and hydroxide under heading 2825 are excluded from the scope of heading 2522 covering quicklime, slaked lime, and hydraulic lime. The Revenue's argument for classifying quicklime under heading 2825 as it occurs last is not legally sustainable. There is no case for applying Rule 3 of General Interpretative Rules. The impugned Order-in-Appeal is set aside, and the appeal is allowed.
The imported goods "Quick Lime" would be properly classifiable under Customs Tariff Item 25221000 and not under Customs Tariff Item 28259090 of the Customs Tariff Act. Quicklime falls under the scope of Chapter 25 covering mineral products like lime and cement, and not under Chapter 28 covering inorganic chemicals. Calcium oxide and hydroxide under heading 2825 are excluded from the scope of heading 2522 covering quicklime, slaked lime, and hydraulic lime. The Revenue's argument for classifying quicklime under heading 2825 as it occurs last is not legally sustainable. There is no case for applying Rule 3 of General Interpretative Rules. The impugned Order-in-Appeal is set aside, and the appeal is allowed.
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