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...
IS 16731/ISO 8217 was treated as a marine-fuel standard, and its scope, safety clauses and flash-point requirements were read contextually to confine Distillate Marine Oil to use on board ships. Applying ejusdem generis, the reference to stationary diesel engines of the same or similar type as marine engines was held not to extend the fuel to industrial use generally, so the petitioner's wider end-use contention failed. The Court also declined to rewrite the prescribed end-use declaration, holding that the maritime regulatory conditions were not shown to be illegal or manifestly arbitrary. Provisional release was therefore made conditional on execution of the declaration in the form required by the authorities, and the writ petition was dismissed.
IS 16731/ISO 8217 was treated as a marine-fuel standard, and its scope, safety clauses and flash-point requirements were read contextually to confine Distillate Marine Oil to use on board ships. Applying ejusdem generis, the reference to stationary diesel engines of the same or similar type as marine engines was held not to extend the fuel to industrial use generally, so the petitioner's wider end-use contention failed. The Court also declined to rewrite the prescribed end-use declaration, holding that the maritime regulatory conditions were not shown to be illegal or manifestly arbitrary. Provisional release was therefore made conditional on execution of the declaration in the form required by the authorities, and the writ petition was dismissed.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4816 
Join Channel 
