Online bond platforms may offer overseas-regulated products and tax-specific bonds subject to disclosures, compliance safeguards and revised complianc...
Corporate guarantee valuation permits actual ascertainable commission while barring retroactive application and extended-period penalties for bona fid...
Proper-officer jurisdiction under UPGST penalty provisions upheld; participation on merits prevents bypassing the statutory appellate remedy through w...
Transitioned CENVAT credit may validly satisfy mandatory pre-deposit requirements for legacy service tax appeals through Electronic Credit Ledger debi...
Building-plan sanction charges require statutory authority; unauthorised fees and GST were quashed, while labour cess must follow prescribed collectio...
Pure-agent exclusion fails where hotel booking facilitators receive third-party services themselves, making entire customer consideration taxable as r...
Transfer pricing comparables were revisited because the stated related party transaction filter exclusions were not supported by the record. The exclusion of I Services India Private Limited required verification of available financial details and fresh computation of the related party transaction percentage before reconsidering inclusion. The exclusion of Cheers Interactive India Private Limited also required recomputation, after excluding payments to key managerial personnel in India from the related party transaction filter, before deciding comparability. On the corporate tax issue, the alleged disallowance of interest on TDS appeared to have been added twice in processing the return, so the Assessing Officer was directed to verify duplication and delete any double addition if established.
Transfer pricing comparables were revisited because the stated related party transaction filter exclusions were not supported by the record. The exclusion of I Services India Private Limited required verification of available financial details and fresh computation of the related party transaction percentage before reconsidering inclusion. The exclusion of Cheers Interactive India Private Limited also required recomputation, after excluding payments to key managerial personnel in India from the related party transaction filter, before deciding comparability. On the corporate tax issue, the alleged disallowance of interest on TDS appeared to have been added twice in processing the return, so the Assessing Officer was directed to verify duplication and delete any double addition if established.
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