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...
In transfer pricing for sale of goods to associated enterprises, the Tribunal accepted TNMM at entity level and rejected the internal cost plus method because earlier coordinate bench decisions on identical facts had already approved TNMM, and no material factual change was shown; the transfer pricing adjustment was deleted. On reversal of provisions, it held that amounts already disallowed when created cannot be taxed again on reversal, but remitted the issue to the Assessing Officer for verification of the claimed accounting mismatch and reconciliation. For short grant of TDS/TCS credit, it directed factual verification from Form 26AS, AIS and supporting records, with due credit to be allowed in accordance with law.
In transfer pricing for sale of goods to associated enterprises, the Tribunal accepted TNMM at entity level and rejected the internal cost plus method because earlier coordinate bench decisions on identical facts had already approved TNMM, and no material factual change was shown; the transfer pricing adjustment was deleted. On reversal of provisions, it held that amounts already disallowed when created cannot be taxed again on reversal, but remitted the issue to the Assessing Officer for verification of the claimed accounting mismatch and reconciliation. For short grant of TDS/TCS credit, it directed factual verification from Form 26AS, AIS and supporting records, with due credit to be allowed in accordance with law.
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