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...
Construction and sale of commercial units on a vacant plot were treated as supply in the course or furtherance of business under GST, because the statutory definition of business is broad enough to cover commercial construction activity regardless of volume, frequency or the applicant's funding source. Sales completed only after receipt of the completion certificate were excluded from GST. Leasing of commercial units was likewise treated as a taxable business activity, so rent formed consideration for a taxable supply. Input tax credit was denied for construction of immovable property on own account, including units retained for lease, because buildings and civil structures are excluded from plant and machinery. Credit was allowed only proportionately for units sold before the occupation or completion certificate.
Construction and sale of commercial units on a vacant plot were treated as supply in the course or furtherance of business under GST, because the statutory definition of business is broad enough to cover commercial construction activity regardless of volume, frequency or the applicant's funding source. Sales completed only after receipt of the completion certificate were excluded from GST. Leasing of commercial units was likewise treated as a taxable business activity, so rent formed consideration for a taxable supply. Input tax credit was denied for construction of immovable property on own account, including units retained for lease, because buildings and civil structures are excluded from plant and machinery. Credit was allowed only proportionately for units sold before the occupation or completion certificate.
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