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 upheld the Ministry of Labour and Employment's notification prohibiting contract labour at Central Warehousing Corporation's Inland Clearance Depot. The court found the work was perennial, necessary for the enterprise, and sufficiently substantial to employ full-time workers. The CACLB's analysis demonstrated proper application of mind under Section 10(2) of the Customs Act, 1962. Specifically, the consistent deployment of approximately 300 contractual labourers over 18 years and similar work performed by regular employees at comparable establishments substantiated the prohibition. The impugned notification was consequently validated, and the petition was disposed of.
HC upheld the Ministry of Labour and Employment's notification prohibiting contract labour at Central Warehousing Corporation's Inland Clearance Depot. The court found the work was perennial, necessary for the enterprise, and sufficiently substantial to employ full-time workers. The CACLB's analysis demonstrated proper application of mind under Section 10(2) of the Customs Act, 1962. Specifically, the consistent deployment of approximately 300 contractual labourers over 18 years and similar work performed by regular employees at comparable establishments substantiated the prohibition. The impugned notification was consequently validated, and the petition was disposed of.
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