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...
Rejection of amendment to a shipping bill was linked to the scope of self-certification, post-export conversion, and a claim for MEIS benefits after the reward box was not marked "YES", which had deprived the authorities of an opportunity to physically verify the goods. The petitioner limited relief to proceeding under the Shipping Bill (Post export conversion in relation to Instrument Based Scheme) Regulations, 2025, so liberty was granted to file an application within two weeks. The application is to be considered in accordance with law after hearing the petitioner, and the decision must be taken uninfluenced by the impugned order.
Rejection of amendment to a shipping bill was linked to the scope of self-certification, post-export conversion, and a claim for MEIS benefits after the reward box was not marked "YES", which had deprived the authorities of an opportunity to physically verify the goods. The petitioner limited relief to proceeding under the Shipping Bill (Post export conversion in relation to Instrument Based Scheme) Regulations, 2025, so liberty was granted to file an application within two weeks. The application is to be considered in accordance with law after hearing the petitioner, and the decision must be taken uninfluenced by the impugned order.
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