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...
Anti-dumping duty imposed on Titanium Dioxide imports from China was set aside after the parent notification was quashed in India Paint Association v. Union of India. The Court noted that the departmental instruction had been issued in light of that earlier ruling and that the petitioner's liability arose solely under the quashed notification. As a result, the order-in-original founded on that notification was also quashed, and the duty already collected was directed to be refunded within twelve weeks.
Anti-dumping duty imposed on Titanium Dioxide imports from China was set aside after the parent notification was quashed in India Paint Association v. Union of India. The Court noted that the departmental instruction had been issued in light of that earlier ruling and that the petitioner's liability arose solely under the quashed notification. As a result, the order-in-original founded on that notification was also quashed, and the duty already collected was directed to be refunded within twelve weeks.
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