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...
Eligible customs arrear cases must be identified for transfer to the Revenue Recovery Unit only after the prescribed appeal period has expired and no appeal, stay, or other proceedings remain pending before any forum. The order requires forwarding such cases with updated TAR particulars, complete e-Office records, the Order-in-Original, any appellate orders, details of stay applications, and a certificate confirming non-pendency of stay under Section 142(1)(c). Complete proposals are to be processed expeditiously, while deficient files may be returned for rectification. An updated Excel statement of transferred cases must be maintained and reflected in future TAR reports to support timely recovery of Government dues.
Eligible customs arrear cases must be identified for transfer to the Revenue Recovery Unit only after the prescribed appeal period has expired and no appeal, stay, or other proceedings remain pending before any forum. The order requires forwarding such cases with updated TAR particulars, complete e-Office records, the Order-in-Original, any appellate orders, details of stay applications, and a certificate confirming non-pendency of stay under Section 142(1)(c). Complete proposals are to be processed expeditiously, while deficient files may be returned for rectification. An updated Excel statement of transferred cases must be maintained and reflected in future TAR reports to support timely recovery of Government dues.
Note: It is a system-generated summary and is for quick reference only.
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