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...
Classification of coconut oil turns on application of Chapter Notes and the Harmonized System: pure coconut oil sold as edible oil falls under Heading 1513 unless its packaging meets all requirements of Chapter Note 3 to Chapter 33 and corresponding HS explanatory notes, in which case it is classifiable under Heading 3305 as hair oil. A binding higher-court decision so holds and the matter is remitted for fresh departmental adjudication to apply that precedent and decide the other issues raised in the impugned Show Cause Notice.
Classification of coconut oil turns on application of Chapter Notes and the Harmonized System: pure coconut oil sold as edible oil falls under Heading 1513 unless its packaging meets all requirements of Chapter Note 3 to Chapter 33 and corresponding HS explanatory notes, in which case it is classifiable under Heading 3305 as hair oil. A binding higher-court decision so holds and the matter is remitted for fresh departmental adjudication to apply that precedent and decide the other issues raised in the impugned Show Cause Notice.
Note: It is a system-generated summary and is for quick reference only.