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...
Non-supply of the relied-upon laboratory material and failure to follow the prescribed procedure before rejecting the declared moisture content breached natural justice, so the assessment could not be sustained and was remanded for fresh adjudication. For ad valorem export duty, transaction value remained the proper basis under section 14 where the invoiced sale proceeds were fully realised and there was no valid reason to doubt the genuineness of the sale price; moisture variation alone did not justify discarding that value. The impugned order was set aside and the matter sent back to the adjudicating authority.
Non-supply of the relied-upon laboratory material and failure to follow the prescribed procedure before rejecting the declared moisture content breached natural justice, so the assessment could not be sustained and was remanded for fresh adjudication. For ad valorem export duty, transaction value remained the proper basis under section 14 where the invoiced sale proceeds were fully realised and there was no valid reason to doubt the genuineness of the sale price; moisture variation alone did not justify discarding that value. The impugned order was set aside and the matter sent back to the adjudicating authority.
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