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 food seasoning material was held classifiable under CTI 3302 10 10 as a mixture based on odoriferous substances. The Tribunal found that Heading 3302 covers mixtures of odoriferous substances, or mixtures with a basis of one or more such substances, and that the presence of parsley, spearmint and paprika oleoresin satisfied that description. It rejected the view that an odoriferous substance must be the main or predominant constituent, holding that the HSN Explanatory Notes do not impose such a requirement. The reclassification under CTI 2103 90 40 was therefore unsustainable and the appeal was allowed.
Imported food seasoning material was held classifiable under CTI 3302 10 10 as a mixture based on odoriferous substances. The Tribunal found that Heading 3302 covers mixtures of odoriferous substances, or mixtures with a basis of one or more such substances, and that the presence of parsley, spearmint and paprika oleoresin satisfied that description. It rejected the view that an odoriferous substance must be the main or predominant constituent, holding that the HSN Explanatory Notes do not impose such a requirement. The reclassification under CTI 2103 90 40 was therefore unsustainable and the appeal was allowed.
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