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...
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Export valuation requires contemporaneous evidence; unrelated invoices cannot prove overvaluation, and dual penalties on firm and partner are impermis...
Statements of key witnesses could not be relied upon where cross-examination was not permitted, especially in light of the High Court's direction that such statements would be unusable without cross-examination. The Tribunal also noted that the certificates of origin issued by the overseas authorities remained valid and had not been cancelled, so the Revenue's allegation that they were improper was unsupported. Following its earlier decision on identical facts, the Tribunal found no infirmity in dropping the proceedings and dismissed the Revenue's appeals.
Statements of key witnesses could not be relied upon where cross-examination was not permitted, especially in light of the High Court's direction that such statements would be unusable without cross-examination. The Tribunal also noted that the certificates of origin issued by the overseas authorities remained valid and had not been cancelled, so the Revenue's allegation that they were improper was unsupported. Following its earlier decision on identical facts, the Tribunal found no infirmity in dropping the proceedings and dismissed the Revenue's appeals.
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