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...
Conditions for provisional release of seized imported commercial goods were held excessive once the differential duty and interest were already secured. The Tribunal noted that the goods were not prohibited and were intended for further manufacture; in one matter, a cash deposit exceeded the secured amount, and in the other, a bond for full value with bank guarantee covering the differential duty and interest had already been furnished and release had followed. It held that revenue interest stood adequately protected, so further insistence was beyond reasonable limits. The release terms were modified and release of the seized goods was directed on execution of a bond for full value.
Conditions for provisional release of seized imported commercial goods were held excessive once the differential duty and interest were already secured. The Tribunal noted that the goods were not prohibited and were intended for further manufacture; in one matter, a cash deposit exceeded the secured amount, and in the other, a bond for full value with bank guarantee covering the differential duty and interest had already been furnished and release had followed. It held that revenue interest stood adequately protected, so further insistence was beyond reasonable limits. The release terms were modified and release of the seized goods was directed on execution of a bond for full value.
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