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 ruled that the delivery agent (Respondent No. 4), registered as an Authorized Sea Agent, is bound by the waiver letter issued by Respondent No. 2. Under Regulations, 2018, the agent cannot demand container detention charges when customs verifies entries and finds them correct. The court directed Respondent No. 4 to release the goods and implement the waiver for detention charges from 24.12.2024 to 10.01.2025, as per Regulation 10(1)(l). The petitioner is exempted from paying detention charges, and the petition was disposed of accordingly.
HC ruled that the delivery agent (Respondent No. 4), registered as an Authorized Sea Agent, is bound by the waiver letter issued by Respondent No. 2. Under Regulations, 2018, the agent cannot demand container detention charges when customs verifies entries and finds them correct. The court directed Respondent No. 4 to release the goods and implement the waiver for detention charges from 24.12.2024 to 10.01.2025, as per Regulation 10(1)(l). The petitioner is exempted from paying detention charges, and the petition was disposed of accordingly.
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