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 manganese ore that had been washed, stripped of waste and sized before shipment was treated as manganese concentrate, not mere ore, for purposes of CVD exemption under Notification No. 04/2006-CE. Applying Chapter Note 4 to Chapter 26 and the HSN explanation, the CESTAT held that processes improving usability or quality and removing foreign matter bring about concentrate as a distinct excisable product. Because the exemption covered only ores, the benefit was unavailable. Following its earlier ruling on similar facts, the Tribunal upheld denial of exemption and dismissed the appeal.
Imported manganese ore that had been washed, stripped of waste and sized before shipment was treated as manganese concentrate, not mere ore, for purposes of CVD exemption under Notification No. 04/2006-CE. Applying Chapter Note 4 to Chapter 26 and the HSN explanation, the CESTAT held that processes improving usability or quality and removing foreign matter bring about concentrate as a distinct excisable product. Because the exemption covered only ores, the benefit was unavailable. Following its earlier ruling on similar facts, the Tribunal upheld denial of exemption and dismissed the appeal.
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