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...
Imported rotary gas meters were classified as gas meters under CTI 9028 10 00 because their essential function was custody transfer measurement of the total volume of gas passed through them, as shown by the product brochure, direct readout and buyer use. The Tribunal held that pressure or flow specifications did not change the instrument's character, so the alternative claim to exemption failed. The extended period of limitation could not be invoked because the documents were filed and the dispute arose from classification, not collusion, wilful misstatement or suppression of facts; the demand survived only for the normal period. Penalty under section 114A was also set aside for the same reason.
Imported rotary gas meters were classified as gas meters under CTI 9028 10 00 because their essential function was custody transfer measurement of the total volume of gas passed through them, as shown by the product brochure, direct readout and buyer use. The Tribunal held that pressure or flow specifications did not change the instrument's character, so the alternative claim to exemption failed. The extended period of limitation could not be invoked because the documents were filed and the dispute arose from classification, not collusion, wilful misstatement or suppression of facts; the demand survived only for the normal period. Penalty under section 114A was also set aside for the same reason.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4800
Join Channel
TaxTMI 
