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...
HC dismissed the appeal, upholding penalties against the appellant for customs duty evasion. The court found the appellant's claims of merely lending his Importer Exporter Code (IEC) to be unsubstantiated. Despite alleging lack of cross-examination opportunity, the court determined the appellant deliberately attempted to evade facts and was complicit with Mr. Rajat Arora in fraudulent import transactions. The appellant was deemed responsible for misuse of his IEC registration and acting in concert with the co-conspirator. Consequently, the original penalties and amounts imposed were confirmed, and the appeal was rejected.
HC dismissed the appeal, upholding penalties against the appellant for customs duty evasion. The court found the appellant's claims of merely lending his Importer Exporter Code (IEC) to be unsubstantiated. Despite alleging lack of cross-examination opportunity, the court determined the appellant deliberately attempted to evade facts and was complicit with Mr. Rajat Arora in fraudulent import transactions. The appellant was deemed responsible for misuse of his IEC registration and acting in concert with the co-conspirator. Consequently, the original penalties and amounts imposed were confirmed, and the appeal was rejected.
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