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...
Gas compressors manufactured solely for use in motor-vehicle air-conditioning units were classified under Heading 8708 as parts and accessories of motor vehicles, not under Heading 8414, because goods meant only for vehicles in Chapter 87 are treated as vehicle parts and the more specific vehicle-heading prevailed. The classification under Heading 8708 was upheld. However, wilful suppression or fraud was not established where the taxpayer had consistently adopted the earlier accepted classification on a bona fide basis, so invocation of Section 74 and the associated penalty were set aside. The matter was remanded only for requantification of tax and fresh determination under Section 73.
Gas compressors manufactured solely for use in motor-vehicle air-conditioning units were classified under Heading 8708 as parts and accessories of motor vehicles, not under Heading 8414, because goods meant only for vehicles in Chapter 87 are treated as vehicle parts and the more specific vehicle-heading prevailed. The classification under Heading 8708 was upheld. However, wilful suppression or fraud was not established where the taxpayer had consistently adopted the earlier accepted classification on a bona fide basis, so invocation of Section 74 and the associated penalty were set aside. The matter was remanded only for requantification of tax and fresh determination under Section 73.
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