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 determined that flavoured milk sold by petitioner falls under tariff heading 0402, not CH 2202. The conversion charges for milk to milk powder were remanded for reassessment, with the appellate authority previously indicating a potential 5% tax rate instead of 18%. The original assessment order and appeal order were set aside, directing the Assessing Officer to conduct a fresh assessment, specifically levying tax on flavoured milk under the specified tariff heading. The petition was subsequently disposed of, effectively returning the matter for reconsideration with specific guidance on tax classification and rate.
HC determined that flavoured milk sold by petitioner falls under tariff heading 0402, not CH 2202. The conversion charges for milk to milk powder were remanded for reassessment, with the appellate authority previously indicating a potential 5% tax rate instead of 18%. The original assessment order and appeal order were set aside, directing the Assessing Officer to conduct a fresh assessment, specifically levying tax on flavoured milk under the specified tariff heading. The petition was subsequently disposed of, effectively returning the matter for reconsideration with specific guidance on tax classification and rate.
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