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...
Demand proceedings for customs duty could not be sustained where the Bills of Entry assessments had not been challenged. The Tribunal held that the Revenue was seeking to dispute the exemption benefit granted at assessment, but the foundational issue was whether any demand action could proceed without first assailing the self-assessment itself. As the assessments had admittedly attained finality and remained unchallenged, the subsequent proceedings against the importer were unsustainable. The impugned order was upheld and the Revenue's appeals were dismissed.
Demand proceedings for customs duty could not be sustained where the Bills of Entry assessments had not been challenged. The Tribunal held that the Revenue was seeking to dispute the exemption benefit granted at assessment, but the foundational issue was whether any demand action could proceed without first assailing the self-assessment itself. As the assessments had admittedly attained finality and remained unchallenged, the subsequent proceedings against the importer were unsustainable. The impugned order was upheld and the Revenue's appeals were dismissed.
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