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...
Para 2.88(a) of the Handbook of Procedures 2023 is amended to add the India-United Kingdom Comprehensive Economic and Trade Agreement to the of FTAs, and Para 2.91(e) is amended to allow Certificates of Origin under India-UK CETA and India-EFTA TEPA to be obtained on the basis of exporter self-declaration, as well as through authorised agencies. The amendment simplifies origin certification for covered exporters by recognising self-declaration as an additional mode for issuance of the Certificate of Origin.
Para 2.88(a) of the Handbook of Procedures 2023 is amended to add the India-United Kingdom Comprehensive Economic and Trade Agreement to the of FTAs, and Para 2.91(e) is amended to allow Certificates of Origin under India-UK CETA and India-EFTA TEPA to be obtained on the basis of exporter self-declaration, as well as through authorised agencies. The amendment simplifies origin certification for covered exporters by recognising self-declaration as an additional mode for issuance of the Certificate of Origin.
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