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...
Certificates of Origin continue to be treated as instruments evidencing the origin of goods imported into any country, and the existing classification into preferential and non-preferential certificates is retained. The list of authorised issuing agencies remains in Appendices 2B, 2C, 2D and 2E. All authorised agencies must now accept applications and issue Certificates of Origin only through the designated electronic platform, currently trade.gov.in, or any other platform DGFT may later designate. Manual issuance outside the prescribed platform is not permitted and may result in revocation of authorisation.
Certificates of Origin continue to be treated as instruments evidencing the origin of goods imported into any country, and the existing classification into preferential and non-preferential certificates is retained. The list of authorised issuing agencies remains in Appendices 2B, 2C, 2D and 2E. All authorised agencies must now accept applications and issue Certificates of Origin only through the designated electronic platform, currently trade.gov.in, or any other platform DGFT may later designate. Manual issuance outside the prescribed platform is not permitted and may result in revocation of authorisation.
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