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 imported pneumatic tyres without the mandatory Bureau of Indian Standards (BIS) markings, violating the provisions of the BIS Act and the Pneumatic Tyres and Tubes of Automatic Vehicles (Quality Control) Order, 2009. The imported tyres were held to be "prohibited goods" u/s 2(33) of the Customs Act, 1962, liable for confiscation u/s 111. The appellant also mis-declared the quantity, quality, and valuation of the imported goods. The Tribunal upheld the absolute confiscation of the goods, imposition of penalties u/ss 112(a)(i) and 114AA of the Customs Act, and rejected the appellant's plea for redemption of the goods, citing public safety concerns and the risk of the goods falling into unauthorized hands.
The appellant imported pneumatic tyres without the mandatory Bureau of Indian Standards (BIS) markings, violating the provisions of the BIS Act and the Pneumatic Tyres and Tubes of Automatic Vehicles (Quality Control) Order, 2009. The imported tyres were held to be "prohibited goods" u/s 2(33) of the Customs Act, 1962, liable for confiscation u/s 111. The appellant also mis-declared the quantity, quality, and valuation of the imported goods. The Tribunal upheld the absolute confiscation of the goods, imposition of penalties u/ss 112(a)(i) and 114AA of the Customs Act, and rejected the appellant's plea for redemption of the goods, citing public safety concerns and the risk of the goods falling into unauthorized hands.
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