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 appellant sought stay of the impugned order citing violation of principles of natural justice due to denial of cross-examination of witnesses in quasi-judicial proceedings related to mis-declaration of quantity and value of goods. The Tribunal held that the appellant repeatedly delayed filing a reply to the show-cause notice and sought cross-examination on flimsy grounds without specifying valid reasons. Relying on Supreme Court precedent, the Tribunal ruled that cross-examination was unwarranted as the officers merely prepared documents based on evidence retrieved, and the appellant failed to contest the statements with specific reasons. Consequently, the appeal was dismissed for lack of merit.
The appellant sought stay of the impugned order citing violation of principles of natural justice due to denial of cross-examination of witnesses in quasi-judicial proceedings related to mis-declaration of quantity and value of goods. The Tribunal held that the appellant repeatedly delayed filing a reply to the show-cause notice and sought cross-examination on flimsy grounds without specifying valid reasons. Relying on Supreme Court precedent, the Tribunal ruled that cross-examination was unwarranted as the officers merely prepared documents based on evidence retrieved, and the appellant failed to contest the statements with specific reasons. Consequently, the appeal was dismissed for lack of merit.
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