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...
An advance ruling application was held non-admissible because it sought to regularise a completed transaction: the prescribed fee had already been paid before the ruling request, so the matter lay outside the advance ruling mechanism. On taxability, the permission granted for conversion of wetland to dry land was treated as a specific regulatory service conferring a direct private benefit, making the statutory fee consideration for supply of service. The activity was held outside the functions entrusted to Panchayats under Article 243G and the Eleventh Schedule, so the claimed exemption failed. Accordingly, GST was held payable under reverse charge on the fee.
An advance ruling application was held non-admissible because it sought to regularise a completed transaction: the prescribed fee had already been paid before the ruling request, so the matter lay outside the advance ruling mechanism. On taxability, the permission granted for conversion of wetland to dry land was treated as a specific regulatory service conferring a direct private benefit, making the statutory fee consideration for supply of service. The activity was held outside the functions entrusted to Panchayats under Article 243G and the Eleventh Schedule, so the claimed exemption failed. Accordingly, GST was held payable under reverse charge on the fee.
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