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 unpaid seller's application for re-exporting goods was accepted; no contravention under the Customs Act, 1962 was committed. While redemption fine is not payable for re-exported goods as per Supreme Court's judgment, considering the facts, redemption fine is reduced to Rs. 5,00,000/-. However, the penalty is upheld. Appeal partly allowed by CESTAT.
The unpaid seller's application for re-exporting goods was accepted; no contravention under the Customs Act, 1962 was committed. While redemption fine is not payable for re-exported goods as per Supreme Court's judgment, considering the facts, redemption fine is reduced to Rs. 5,00,000/-. However, the penalty is upheld. Appeal partly allowed by CESTAT.
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