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...
Wall rent paid for sites used to display advertisements was held includible in the taxable value of advertising agency service because it was an intrinsic and inseparable part of the service, and the assessee failed to establish a valid pure agent arrangement or direct contractual link between clients and wall owners. By contrast, the value of printed flex material supplied through a separately registered concern, separately invoiced and taxed as goods, was held not includible under the service tax valuation rules or Notification No. 12/2003-ST. The extended limitation period was rejected because suppression or wilful misstatement was not proved in an audit-based notice, and penalties were deleted as the dispute was interpretational.
Wall rent paid for sites used to display advertisements was held includible in the taxable value of advertising agency service because it was an intrinsic and inseparable part of the service, and the assessee failed to establish a valid pure agent arrangement or direct contractual link between clients and wall owners. By contrast, the value of printed flex material supplied through a separately registered concern, separately invoiced and taxed as goods, was held not includible under the service tax valuation rules or Notification No. 12/2003-ST. The extended limitation period was rejected because suppression or wilful misstatement was not proved in an audit-based notice, and penalties were deleted as the dispute was interpretational.
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