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...
Consideration of transaction value and sequential redetermination under CVR rules is central, with rejection of declared value under Rule 12 followed by rules 3-9 valuation steps; the piece emphasises shifting onus and distinct burdens of proof in valuation disputes and accepts electronic records and account statements where authenticity is undisputed. It notes provisional assessments prevent attraction of penal provisions and, despite upholding assessable values after investigation and non-traversal by the importer, recommends setting aside confiscation, fines and penalties while allowing consequential relief as per law.
Consideration of transaction value and sequential redetermination under CVR rules is central, with rejection of declared value under Rule 12 followed by rules 3-9 valuation steps; the piece emphasises shifting onus and distinct burdens of proof in valuation disputes and accepts electronic records and account statements where authenticity is undisputed. It notes provisional assessments prevent attraction of penal provisions and, despite upholding assessable values after investigation and non-traversal by the importer, recommends setting aside confiscation, fines and penalties while allowing consequential relief as per law.
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