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, a job worker, violated Rules 6 and 10A of the Central Excise Valuation Rules by not including the value of free supply material from the prime manufacturer while clearing job-worked goods on payment of duty. This amounted to suppression of facts with intent to evade duty, invoking the extended period of limitation u/s 11A(4). The assessable value should have included the value of raw materials supplied for job work, as per Supreme Court decisions. The benefit of Notification 214/86-CE was not admissible due to non-compliance with conditions. Rule 10A provided definiteness for valuation of goods manufactured and cleared by job workers.
The appellant, a job worker, violated Rules 6 and 10A of the Central Excise Valuation Rules by not including the value of free supply material from the prime manufacturer while clearing job-worked goods on payment of duty. This amounted to suppression of facts with intent to evade duty, invoking the extended period of limitation u/s 11A(4). The assessable value should have included the value of raw materials supplied for job work, as per Supreme Court decisions. The benefit of Notification 214/86-CE was not admissible due to non-compliance with conditions. Rule 10A provided definiteness for valuation of goods manufactured and cleared by job workers.
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