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...
Paddle wheel aerators used exclusively in aquaculture are correctly classified under HSN 84798999 because their primary function is mechanical water agitation and oxygen transfer rather than terrestrial agricultural operations; therefore HSN 8479, as a residual heading for machines with specific functions not elsewhere specified, applies and the unit remains in 84798999. Recent GST rate rationalisation granting a concessional 5% rate to aerators operates by rate notification and does not reclassify goods into HSN 8436; consequently the aerators retain their 8479 classification and associated tariff treatment. Parts exclusively used with these aerators follow the principal machine classification and are not reallocated to 8436.
Paddle wheel aerators used exclusively in aquaculture are correctly classified under HSN 84798999 because their primary function is mechanical water agitation and oxygen transfer rather than terrestrial agricultural operations; therefore HSN 8479, as a residual heading for machines with specific functions not elsewhere specified, applies and the unit remains in 84798999. Recent GST rate rationalisation granting a concessional 5% rate to aerators operates by rate notification and does not reclassify goods into HSN 8436; consequently the aerators retain their 8479 classification and associated tariff treatment. Parts exclusively used with these aerators follow the principal machine classification and are not reallocated to 8436.
Note: It is a system-generated summary and is for quick reference only.