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...
Transportation and insurance charges recovered for moving goods were not taxable as business support service where the appellant was not acting as a goods transport agency issuing consignment notes; transportation by road by a person other than a GTA remained outside the levy, and the insurance element was treated as bundled with transport. Reverse charge on accounting services supplied to the Ethiopian branch also failed because the services were received and used in Ethiopia, with the branch and Indian office treated as separate permanent establishments. The extended period of limitation was unavailable because the demand rested on disclosed balance-sheet figures, so the related penalty, interest, and remaining penalties also fell.
Transportation and insurance charges recovered for moving goods were not taxable as business support service where the appellant was not acting as a goods transport agency issuing consignment notes; transportation by road by a person other than a GTA remained outside the levy, and the insurance element was treated as bundled with transport. Reverse charge on accounting services supplied to the Ethiopian branch also failed because the services were received and used in Ethiopia, with the branch and Indian office treated as separate permanent establishments. The extended period of limitation was unavailable because the demand rested on disclosed balance-sheet figures, so the related penalty, interest, and remaining penalties also fell.
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