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...
Entry Inward and Vessel Sail-out Clearance must be granted promptly on filing the requisite documents, including Sea Arrival Manifest and Sea Departure Manifest, and completion of prescribed checks, without insisting on physical boarding of the vessel. The circular clarifies that entry inward, sail-out clearance, and boarding are separate statutory processes under the Customs Act, 1962, and that boarding under section 37 is independent of clearance formalities. Physical boarding by Customs officers is to be undertaken on a risk-based basis, with field formations required to consider compliance behaviour, voyage pattern, cargo nature and other relevant safety and security parameters.
Entry Inward and Vessel Sail-out Clearance must be granted promptly on filing the requisite documents, including Sea Arrival Manifest and Sea Departure Manifest, and completion of prescribed checks, without insisting on physical boarding of the vessel. The circular clarifies that entry inward, sail-out clearance, and boarding are separate statutory processes under the Customs Act, 1962, and that boarding under section 37 is independent of clearance formalities. Physical boarding by Customs officers is to be undertaken on a risk-based basis, with field formations required to consider compliance behaviour, voyage pattern, cargo nature and other relevant safety and security parameters.
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