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 dispute over an agro-product: the article identifies the legal issue as whether low percentages of N, P, K render those elements non-essential and thus the product falls under a general chemical heading rather than fertiliser. It notes heavy reliance on an incomplete laboratory test report and that the appellate order failed to address invocation of the extended limitation period. The piece records remand to the adjudicating authority for fresh classification adjudication, direction to resolve outstanding lab-query and limitation points, and to decide afresh observing principles of natural justice within six months.
Classification dispute over an agro-product: the article identifies the legal issue as whether low percentages of N, P, K render those elements non-essential and thus the product falls under a general chemical heading rather than fertiliser. It notes heavy reliance on an incomplete laboratory test report and that the appellate order failed to address invocation of the extended limitation period. The piece records remand to the adjudicating authority for fresh classification adjudication, direction to resolve outstanding lab-query and limitation points, and to decide afresh observing principles of natural justice within six months.
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