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...
For notified goods such as gold, seizure on reasonable belief initially shifts the burden to the person concerned to prove lawful acquisition under Section 123. The appellate authority's absolute release of the seized gold was unsustainable because it accepted books, invoices and GST records without correlating the entries or addressing discrepancies and the admitted fabrication of invoices and stock records. The order was therefore set aside and the matter remanded for fresh examination of the documentary evidence and the Revenue's grounds. The limitation objection to the show-cause notice was rejected, as the notice was covered by the statutory extension under the relaxation law and the objection had not been raised below.
For notified goods such as gold, seizure on reasonable belief initially shifts the burden to the person concerned to prove lawful acquisition under Section 123. The appellate authority's absolute release of the seized gold was unsustainable because it accepted books, invoices and GST records without correlating the entries or addressing discrepancies and the admitted fabrication of invoices and stock records. The order was therefore set aside and the matter remanded for fresh examination of the documentary evidence and the Revenue's grounds. The limitation objection to the show-cause notice was rejected, as the notice was covered by the statutory extension under the relaxation law and the objection had not been raised below.
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