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...
CESTAT adjudicated a complex customs proceedings case involving procedural safeguards under Section 155 of Customs Act, 1962. The tribunal found that the original authority improperly evaluated 'good faith' and statutory limitations, thereby violating procedural protections for customs officers. The appellate tribunal critically examined the adjudication process, highlighting the importance of adhering to statutory limitations and procedural safeguards. Consequently, the appeals were allowed, with the case remanded to the original adjudicating authority for reconsideration, emphasizing that procedural integrity is paramount in administrative and quasi-judicial proceedings against government officers.
CESTAT adjudicated a complex customs proceedings case involving procedural safeguards under Section 155 of Customs Act, 1962. The tribunal found that the original authority improperly evaluated 'good faith' and statutory limitations, thereby violating procedural protections for customs officers. The appellate tribunal critically examined the adjudication process, highlighting the importance of adhering to statutory limitations and procedural safeguards. Consequently, the appeals were allowed, with the case remanded to the original adjudicating authority for reconsideration, emphasizing that procedural integrity is paramount in administrative and quasi-judicial proceedings against government officers.
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