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...
ICT@ Schools services were treated as one naturally bundled composite supply, with infrastructure, software, maintenance, teacher training and student instruction forming an integrated education service under the BOOT model. Applying the predominant nature test, the Tribunal held that the ICT platform was only the medium for delivering curriculum-based computer education in schools, so the services fell within the education exemption under the negative list up to 13.05.2016 and continued to be exempt under the amended Mega Exemption Notification thereafter. Because the activities were not taxable during the disputed period, the valuation and abatement objections were academic, and the Revenue's challenge was held not maintainable.
ICT@ Schools services were treated as one naturally bundled composite supply, with infrastructure, software, maintenance, teacher training and student instruction forming an integrated education service under the BOOT model. Applying the predominant nature test, the Tribunal held that the ICT platform was only the medium for delivering curriculum-based computer education in schools, so the services fell within the education exemption under the negative list up to 13.05.2016 and continued to be exempt under the amended Mega Exemption Notification thereafter. Because the activities were not taxable during the disputed period, the valuation and abatement objections were academic, and the Revenue's challenge was held not maintainable.
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