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 modified the customs assessment order involving undervaluation of imported networking equipment. The tribunal found the importer's initial declaration of USD 100 versus actual value of USD 64,496.42 was due to inter-office correspondence error, not intentional duty evasion. While confirming penalty under Section 112(ii), the tribunal set aside penalty under Section 114AA and reduced the redemption fine from Rs. 10,00,000 to Rs. 5,00,000, considering the importer's immediate disclosure and cooperative approach. The appeal was disposed of with partial relief to the appellant, balancing procedural compliance with substantive justice.
CESTAT modified the customs assessment order involving undervaluation of imported networking equipment. The tribunal found the importer's initial declaration of USD 100 versus actual value of USD 64,496.42 was due to inter-office correspondence error, not intentional duty evasion. While confirming penalty under Section 112(ii), the tribunal set aside penalty under Section 114AA and reduced the redemption fine from Rs. 10,00,000 to Rs. 5,00,000, considering the importer's immediate disclosure and cooperative approach. The appeal was disposed of with partial relief to the appellant, balancing procedural compliance with substantive justice.
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