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...
Subsequent purchasers of imported vehicles were not liable for differential customs duty arising from alleged misdeclaration of the year of manufacture, because they were not involved in the importation and could not be treated as importers for recovery under customs law. A joint and several demand confirmed against importers and purchasers was therefore unsustainable, following the governing Supreme Court principle on the definition of importer and recovery of duty. The penalties imposed on the purchasers also failed because they were consequential to the unsustainable duty demand. The Tribunal set aside the impugned orders and granted consequential relief.
Subsequent purchasers of imported vehicles were not liable for differential customs duty arising from alleged misdeclaration of the year of manufacture, because they were not involved in the importation and could not be treated as importers for recovery under customs law. A joint and several demand confirmed against importers and purchasers was therefore unsustainable, following the governing Supreme Court principle on the definition of importer and recovery of duty. The penalties imposed on the purchasers also failed because they were consequential to the unsustainable duty demand. The Tribunal set aside the impugned orders and granted consequential relief.
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