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...
The Tribunal held that identical Electronic Power Steering ECU goods were governed by its earlier final order in the appellant's own case, and that binding coordinate-bench discipline required the same classification result because the earlier order had not been stayed despite challenge. It distinguished the later Chennai Bench view, noting that decision did not consider the appellant's prior case and turned on different facts. On that basis, EPS-ECU remained classifiable under CTI 8708 94 00 and not under CTI 9032 90 00. The impugned classification was upheld and the appeals were dismissed.
The Tribunal held that identical Electronic Power Steering ECU goods were governed by its earlier final order in the appellant's own case, and that binding coordinate-bench discipline required the same classification result because the earlier order had not been stayed despite challenge. It distinguished the later Chennai Bench view, noting that decision did not consider the appellant's prior case and turned on different facts. On that basis, EPS-ECU remained classifiable under CTI 8708 94 00 and not under CTI 9032 90 00. The impugned classification was upheld and the appeals were dismissed.
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