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 appeals were maintainable as the show cause notice issued by the Adjudicating Authority raised issues pertaining to mis-declaration of description and value addition to wrongly claim benefit under the replenishment scheme, applicability of Notification No. 57/2000-Customs and Circular No. 27/206-Customs, and the Foreign Trade Policy 2015-20. The Court found no substantial questions of law arising for consideration, as the demand for duty on the quantum of gold received under the replenishment scheme was not disputed, and the findings of fact were properly appreciated based on the available record. Consequently, the appeals were dismissed.
The High Court held that the appeals were maintainable as the show cause notice issued by the Adjudicating Authority raised issues pertaining to mis-declaration of description and value addition to wrongly claim benefit under the replenishment scheme, applicability of Notification No. 57/2000-Customs and Circular No. 27/206-Customs, and the Foreign Trade Policy 2015-20. The Court found no substantial questions of law arising for consideration, as the demand for duty on the quantum of gold received under the replenishment scheme was not disputed, and the findings of fact were properly appreciated based on the available record. Consequently, the appeals were dismissed.
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