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 must rest on reliable, internally consistent financial data: MSL Driveline was excluded because its annual report and financial statements conflicted on related party transactions, and the threshold was treated as crossed. Under TNMM, the persistent loss filter turns on operating profit, not profit before tax, and a company with profit in one relevant year is not a persistent loss-maker; Bharat Gears Ltd. and JMT Auto Ltd. were therefore to be included. In a capital-intensive manufacturing business, depreciation differences may warrant adjustment if they materially affect margins. Transfer pricing adjustment is confined to AE transactions, not entity-level non-AE dealings. An intimation under section 143(1) issued after notice under section 143(2) lacked jurisdiction, so the adjustments were deleted.
Transfer pricing comparables must rest on reliable, internally consistent financial data: MSL Driveline was excluded because its annual report and financial statements conflicted on related party transactions, and the threshold was treated as crossed. Under TNMM, the persistent loss filter turns on operating profit, not profit before tax, and a company with profit in one relevant year is not a persistent loss-maker; Bharat Gears Ltd. and JMT Auto Ltd. were therefore to be included. In a capital-intensive manufacturing business, depreciation differences may warrant adjustment if they materially affect margins. Transfer pricing adjustment is confined to AE transactions, not entity-level non-AE dealings. An intimation under section 143(1) issued after notice under section 143(2) lacked jurisdiction, so the adjustments were deleted.
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