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 commissioning of an underground sewerage scheme was treated as a composite works contract, not a pure service, because it involved construction of sewer networks, wet-wells, pump-houses, rising mains, treatment plant, and supply, erection, testing and commissioning of equipment. For Entry 3A exemption, the Authority held that the goods-value test applies to the composite supply as a whole, not to separate sub-units, and that a Nagar Parishad qualifies as a local authority. It also found the sewerage work related to municipal public health and sanitation functions under Article 243W. Exemption was available from 25.01.2018 on the record, but only conditionally, if the actual goods component at completion did not exceed 25% of the contract value.
Construction and commissioning of an underground sewerage scheme was treated as a composite works contract, not a pure service, because it involved construction of sewer networks, wet-wells, pump-houses, rising mains, treatment plant, and supply, erection, testing and commissioning of equipment. For Entry 3A exemption, the Authority held that the goods-value test applies to the composite supply as a whole, not to separate sub-units, and that a Nagar Parishad qualifies as a local authority. It also found the sewerage work related to municipal public health and sanitation functions under Article 243W. Exemption was available from 25.01.2018 on the record, but only conditionally, if the actual goods component at completion did not exceed 25% of the contract value.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4807 
Join Channel 
