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...
Washing, removal of waste and sizing of imported manganese ore were treated as processes that converted run-of-mine ore into manganese concentrates. The Tribunal, following its earlier ruling, held that where such processing changes ore into concentrate under the chapter note and HSN explanation, the concentrate becomes distinct from ore in law. An exemption confined to manganese ores could not be extended to concentrates, so the claimed CVD exemption was not available. The imported goods were therefore correctly classified as manganese concentrates, and denial of the notification benefit was upheld.
Washing, removal of waste and sizing of imported manganese ore were treated as processes that converted run-of-mine ore into manganese concentrates. The Tribunal, following its earlier ruling, held that where such processing changes ore into concentrate under the chapter note and HSN explanation, the concentrate becomes distinct from ore in law. An exemption confined to manganese ores could not be extended to concentrates, so the claimed CVD exemption was not available. The imported goods were therefore correctly classified as manganese concentrates, and denial of the notification benefit was upheld.
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