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...
Section 129 is described as a complete code for detention and release of goods in transit, requiring release on payment of the prescribed penalty where the owner or another person comes forward, without treating detention as a continuing lien pending final adjudication of the demand. On the facts discussed, objections regarding ownership, quantity, quality and supporting documents were not backed by contrary material sufficient to displace the petitioner's claim of ownership at that stage. The consignment was therefore directed to be released on compliance with Section 129(1)(a), while the revenue was left free to recover any finally sustained demand in accordance with law.
Section 129 is described as a complete code for detention and release of goods in transit, requiring release on payment of the prescribed penalty where the owner or another person comes forward, without treating detention as a continuing lien pending final adjudication of the demand. On the facts discussed, objections regarding ownership, quantity, quality and supporting documents were not backed by contrary material sufficient to displace the petitioner's claim of ownership at that stage. The consignment was therefore directed to be released on compliance with Section 129(1)(a), while the revenue was left free to recover any finally sustained demand in accordance with law.
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