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...
Solar inverters supplied for use in solar power generating systems were treated as integral parts of that system and, on the material produced, fell within Sl. No. 234 of Notification No. 1/2017-CT(R), attracting GST at 5%. The Court held that the concession extends to parts used for manufacture of solar power generating systems, and that assembling such parts into a new product with a distinct name, character and use satisfies the definition of manufacture. It also held that expressions such as "required to manufacture" and "for use" refer to intended use, so proof of actual end-use was not necessary. The contrary orders were quashed to that extent.
Solar inverters supplied for use in solar power generating systems were treated as integral parts of that system and, on the material produced, fell within Sl. No. 234 of Notification No. 1/2017-CT(R), attracting GST at 5%. The Court held that the concession extends to parts used for manufacture of solar power generating systems, and that assembling such parts into a new product with a distinct name, character and use satisfies the definition of manufacture. It also held that expressions such as "required to manufacture" and "for use" refer to intended use, so proof of actual end-use was not necessary. The contrary orders were quashed to that extent.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4814 
Join Channel 
