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Income Tax Govt

Tax Tribunal Jaipur Strikes Down Rs 29.25 Crore Addition Using Berry Ratio

The Jaipur bench of the Income Tax Appellate Tribunal deleted a tax addition of Rs 29.25 crore for a jewellery manufacturer. The tribunal ruled that the Berry ratio is unsuitable for businesses that transform raw materials into finished products. This decision provides significant relief to taxpayers challenging inappropriate transfer pricing methods.

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For professionals: The ITAT Jaipur ruled that the Berry ratio is not suitable for jewellery manufacturing entities that alter raw materials into finished goods. · Tax professionals can use this precedent to challenge the incorrect application of financial metrics that distort profitability assessments for manufacturing clients. · Functional profiles must dictate the choice of evaluation metrics over rigid statistical formulas.

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Taxguru10m ago 1 min
Income Tax Govt

ITAT Jaipur rules berry ratio inapplicable for transfer pricing in jewellery manufacturing

The Jaipur bench of the Income Tax Appellate Tribunal ruled that the berry ratio does not apply to a jewellery manufacturing entity in a transfer pricing case. This decision provides clarity on appropriate profit-level indicators for precious metal and ornament producers during international transactions. Tax professionals must evaluate functional profiles carefully before applying specific financial ratios.

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For professionals: Evaluate transfer pricing documentation for manufacturing clients to ensure distributor-focused metrics like the berry ratio are not inappropriately applied · Advise jewellery manufacturing clients that standard intermediary metrics do not fit actual manufacturing activities under established transfer pricing principles

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Taxguru11m ago 1 min
Markets

Mold-Tek Technologies Hits Upper Circuit Following Record Quarter Earnings

Shares of Mold-Tek Technologies hit the five percent upper circuit for four consecutive sessions after posting record financial results. Revenue for the second quarter of financial year 2027 surged by 51.2 percent year on year to reach Rs 60.81 crore. Meanwhile, net profit skyrocketed by 197.32 percent to hit Rs 9.62 crore.

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For professionals: No tax, regulatory, filing, or statutory compliance updates or sections are stated in the text · Professional advisory scope is limited to monitoring upcoming quarterly disclosures and trading volumes for Mold-Tek Technologies equities

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LiveMint Markets13m ago 1 min
Business

Gujarat high court sets aside assessment year 2014-15 notice exceeding ten-year limit

The Gujarat High Court quashed a reassessment notice issued for the assessment year 2014-15 because it exceeded the permissible ten-year statutory limit. This judgment reinforces strict adherence to limitation periods governing tax reopening proceedings under corporate law. Taxpayers facing delayed scrutiny notices can rely on this precedent to challenge jurisdictional overreach.

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For professionals: Advise clients to audit historical reassessment notices received to check if they exceed statutory limitation periods. · Review past tax assessments to ensure compliance with temporal boundaries and protect clients from unending litigation.

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Taxguru15m ago 1 min
Income Tax Govt

ITAT Jaipur rejects berry ratio for jewellery producer in transfer pricing dispute

The Income Tax Appellate Tribunal in Jaipur rejected the use of the berry ratio for a jewellery manufacturer during a transfer pricing dispute. The ruling establishes that intermediary profitability metrics do not apply to industrial producers engaged in material transformation. Tax practitioners must ensure transfer pricing studies use appropriate profit indicators matching client operations.

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For professionals: The Jaipur bench of the Income Tax Appellate Tribunal rejected the application of the berry ratio to a jewellery manufacturer in a transfer pricing proceeding. · The tribunal determined that utilizing distributor-oriented benchmarks for a manufacturing enterprise is methodologically incorrect because the berry ratio is suitable for low-risk distributors and traders rather than entities that manufacture goods and assume full operational and market risks. · Tax professionals and chartered accountants must carefully examine transfer pricing documentation for manufacturing clients to ensure proper profit-level indicators are selected based on precise functional analysis.

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Taxguru16m ago 1 min
Business Breaking

Indian Gold Market Anticipates Twelve Percent Rise in Dhanteras Demand

The domestic gold market expects a twelve percent increase in consumer demand during the upcoming Dhanteras festival. This projected growth reflects strong consumer enthusiasm despite elevated precious metal prices. Retail jewellers are preparing for robust footfall as buyers traditionally purchase gold as a sign of prosperity.

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For professionals: Industry professionals should monitor sales volume reports, import data, and consumer sentiment indices following the festival week. · Practitioners advising retail bullion establishments and jewellery business owners must note that festive demand acts as a stabilizing force for domestic bullion prices and provides significant revenue boosts for organized and unorganized retail jewellers.

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Economic Times18m ago 1 min
Income Tax

Gujarat High Court sets aside income tax reassessment notice exceeding the ten-year search limit

The Gujarat High Court has set aside an income tax reassessment notice because it crossed the ten-year search limit. This judgment provides relief to taxpayers facing prolonged scrutiny regarding past financial years. Legal experts highlight the importance of adhering to statutory timeframes during tax audits.

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For professionals: Review active scrutiny notices against the statutory ten-year threshold to identify potential jurisdictional flaws. · Document the exact dates of search actions and subsequent notices to mount effective legal challenges if timelines are breached. · Verify the exact issuance dates of legacy tax notices to safeguard your clients or organization from time-barred proceedings.

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Taxguru20m ago 1 min
Income Tax

Delhi High Court rules business process and knowledge process outsourcing firms are not comparable

The Delhi High Court has ruled that Business Process Outsourcing (BPO) and Knowledge Process Outsourcing (KPO) firms cannot be treated as comparable for transfer pricing assessments. This decision prevents tax authorities from using dissimilar entities as benchmarks for international transactions. Tax practitioners can leverage this ruling to dispute improper comparable company selections.

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For professionals: Tax professionals handling transfer pricing litigation should cite this ruling when tax authorities attempt to benchmark BPO operations against KPO margins. · Finance teams must analyze the functional profile, asset intensity, and risk parameters of chosen comparables before filing transfer pricing documentation. · Distinct business models require independent benchmarking to avoid arbitrary tax adjustments on multinational enterprises as established by this judicial clarity.

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Taxguru21m ago 1 min
RBI/SEBI Govt Breaking

Sitaram Denims India submits initial public offering draft papers to market regulator

Sitaram Denims India Ltd has submitted preliminary IPO documents to the Securities and Exchange Board of India (Sebi). The public offering features a fresh issue of equity shares alongside an offer for sale by existing promoters. Funds raised will support debt repayment, working capital needs, and the establishment of a new garment manufacturing plant in Bhilwara.

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For professionals: Market participants, merchant bankers, and investors should review the draft red herring prospectus for detailed financial statements, risk factors, and promoter track records. · Companies planning similar capital raises must align their fund-utilization schedules with regulatory disclosure norms.

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ET Markets22m ago 1 min
Business

Supreme Court refuses to touch quashed Section 153C notice over delayed satisfaction note

The Supreme Court declined to interfere with the quashing of a Section 153C notice. The notice faced dismissal because the required satisfaction note was delayed. This ruling upholds the strict timeline requirements for tax proceedings.

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For professionals: Verify exact dates and timestamps on satisfaction notes when defending clients against search assessments under Section 153C of the Income Tax Act. · Advise clients to challenge any procedural delays in recording satisfaction during search and seizure proceedings before appellate authorities.

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Taxguru24m ago 1 min
Business

Madras High Court sets aside Section 148A orders for denying mandatory seven-day reply window

The Madras High Court set aside Section 148A orders because authorities denied the mandatory seven-day reply time. This decision reinforces procedural fairness in tax reassessment proceedings. Taxpayers must receive proper windows to respond before authorities issue further notices.

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For professionals: Review all recent client reassessment orders immediately to identify similar procedural lapses regarding reply timelines. · File writ petitions or representations when authorities truncate response times and ensure all communication records are properly maintained.

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Taxguru25m ago 1 min
Economy Breaking

Nintendo Switch 2 sales plummet 41 percent following price hikes and soaring memory costs

Nintendo reported a 41 percent sales plunge for its flagship Switch 2 during the fiscal second quarter. The drop followed price hikes implemented by the Japanese gaming giant due to soaring memory costs. Market headwinds and component expense pressures severely impacted quarterly performance.

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For professionals: Nintendo recorded a 41 percent sales plunge for its flagship Switch 2 during its fiscal second quarter. Retail investors and market analysts monitoring consumer discretionary stocks should track how hardware manufacturers manage supply chain inflation without eroding sales volume. Stakeholders should review quarterly earnings reports and hardware shipment metrics to assess future margin recovery potential.

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CNBC Global28m ago 1 min

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