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...
All four imported products were classified as relays under CTI 8536 49 00 because their principal function was to control, protect and supervise electrical systems, and the added digital or monitoring features were only ancillary under the principal function test and trade parlance. Exemption under Notification No. 12/2012 was available to the three products with a contact rating of 5 amperes, as no contrary evidence showed them to exceed the 7-ampere limit; MICOM was excluded because its contact rating above 7 amperes was not disputed. Penalties under sections 114A, 114AA, 112 and 114AA were set aside since the demand failed for the three products and the duty and interest relating to MICOM had been paid before the show cause notice.
All four imported products were classified as relays under CTI 8536 49 00 because their principal function was to control, protect and supervise electrical systems, and the added digital or monitoring features were only ancillary under the principal function test and trade parlance. Exemption under Notification No. 12/2012 was available to the three products with a contact rating of 5 amperes, as no contrary evidence showed them to exceed the 7-ampere limit; MICOM was excluded because its contact rating above 7 amperes was not disputed. Penalties under sections 114A, 114AA, 112 and 114AA were set aside since the demand failed for the three products and the duty and interest relating to MICOM had been paid before the show cause notice.
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