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...
The BoA for SEZs ratified the minutes of its previous meeting and granted a one-year extension of validity of the Letter of Approval for an SEZ unit that had completed construction and installation but awaited USFDA-related commencement. It approved an increase in development rights and land area for an existing co-developer at GIFT-SEZ, subject to SEZ terms and tax examination by the assessing authority. The Board also approved partial de-notification of land from an IT/ITES SEZ, permitted multiple demarcations of processing built-up area as non-processing area under Rule 11B after repayment of duty benefits and issue of no-dues certificates, approved merger of two adjacent sector-specific SEZs into one multi-sector SEZ, and remanded an appeal against cancellation of a unit's LoA for fresh decision after reasonable hearing.
The BoA for SEZs ratified the minutes of its previous meeting and granted a one-year extension of validity of the Letter of Approval for an SEZ unit that had completed construction and installation but awaited USFDA-related commencement. It approved an increase in development rights and land area for an existing co-developer at GIFT-SEZ, subject to SEZ terms and tax examination by the assessing authority. The Board also approved partial de-notification of land from an IT/ITES SEZ, permitted multiple demarcations of processing built-up area as non-processing area under Rule 11B after repayment of duty benefits and issue of no-dues certificates, approved merger of two adjacent sector-specific SEZs into one multi-sector SEZ, and remanded an appeal against cancellation of a unit's LoA for fresh decision after reasonable hearing.
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