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...
GST applies to actionable claims arising from betting and gambling because the taxable event is supply, and actionable claims can validly be treated as goods within the GST framework. Staking money on an uncertain outcome, whether in online gaming, fantasy sports or casinos, gives the transaction the character of betting and gambling; the online medium and elements of skill do not alter that result where stakes are involved. The full stake amount appropriated for participation forms consideration and enters valuation. Rules 31A, 31B and 31C, and the 2023 amendments, were upheld as valid, clarificatory and retrospective machinery provisions. Casino valuation was left to be recomputed under Rule 31C, while the challenge to the GST levy and related notices failed.
GST applies to actionable claims arising from betting and gambling because the taxable event is supply, and actionable claims can validly be treated as goods within the GST framework. Staking money on an uncertain outcome, whether in online gaming, fantasy sports or casinos, gives the transaction the character of betting and gambling; the online medium and elements of skill do not alter that result where stakes are involved. The full stake amount appropriated for participation forms consideration and enters valuation. Rules 31A, 31B and 31C, and the 2023 amendments, were upheld as valid, clarificatory and retrospective machinery provisions. Casino valuation was left to be recomputed under Rule 31C, while the challenge to the GST levy and related notices failed.
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