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...
Goods falling under sub-heading 16010000 were outside Notification No. 125/2011-Cus. because the annexure expressly excluded heading/sub-heading 160100, so the original exemption claim failed. The alternate claim under Notification No. 26/2000-Cus. was also rejected because a conditional exemption required supporting documents, and new material could not be introduced for the first time in appeal without compliance with the procedure for additional evidence under Rule 23. The limitation objection was denied as the one-year period under Section 28 of the Customs Act ran from the end of the month of filing of the bill of entry, making the demand notice timely.
Goods falling under sub-heading 16010000 were outside Notification No. 125/2011-Cus. because the annexure expressly excluded heading/sub-heading 160100, so the original exemption claim failed. The alternate claim under Notification No. 26/2000-Cus. was also rejected because a conditional exemption required supporting documents, and new material could not be introduced for the first time in appeal without compliance with the procedure for additional evidence under Rule 23. The limitation objection was denied as the one-year period under Section 28 of the Customs Act ran from the end of the month of filing of the bill of entry, making the demand notice timely.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4807 
Join Channel 
