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...
Mixed iron ore consignments exported under final self-assessed shipping bills were to be treated as iron ore fines as a whole, and the higher rate for lumps could not be applied by splitting the cargo. For ad valorem export duty, the declared moisture content, Fe content and assessable value at the time of export had to be adopted; subsequent BRC-based realization figures could not replace the declared values. The Tribunal upheld invocation of the extended period and penalty because the declarations were found to be incorrect and material facts had been withheld, and remanded only for recomputation of any differential duty on that basis.
Mixed iron ore consignments exported under final self-assessed shipping bills were to be treated as iron ore fines as a whole, and the higher rate for lumps could not be applied by splitting the cargo. For ad valorem export duty, the declared moisture content, Fe content and assessable value at the time of export had to be adopted; subsequent BRC-based realization figures could not replace the declared values. The Tribunal upheld invocation of the extended period and penalty because the declarations were found to be incorrect and material facts had been withheld, and remanded only for recomputation of any differential duty on that basis.
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