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 customs seizure case involving gold bars transported between cities. The tribunal found the seizure invalid due to lack of substantive evidence. Key determinations included: (1) the primary statement constituted hearsay testimony, (2) no corroborative documentation established smuggling, and (3) the revenue authority failed to demonstrate reasonable belief under Section 110 of the Customs Act. The tribunal rejected revenue's arguments regarding tax invoice dates and procedural objections. Consequently, the tribunal sustained the Commissioner (Appeals) order, dismissing the revenue's appeal and nullifying the original confiscation and penalty orders against the individual.
CESTAT adjudicated a customs seizure case involving gold bars transported between cities. The tribunal found the seizure invalid due to lack of substantive evidence. Key determinations included: (1) the primary statement constituted hearsay testimony, (2) no corroborative documentation established smuggling, and (3) the revenue authority failed to demonstrate reasonable belief under Section 110 of the Customs Act. The tribunal rejected revenue's arguments regarding tax invoice dates and procedural objections. Consequently, the tribunal sustained the Commissioner (Appeals) order, dismissing the revenue's appeal and nullifying the original confiscation and penalty orders against the individual.
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