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...
DSCL qualified as a Governmental Authority because it was a government-established special purpose vehicle with 90% or more governmental equity/control and was set up to implement urban local body functions. Its services for the Smart City/ESCO water-supply project to UJS were exempt under Serial No. 4 of Notification No. 12/2017-Central Tax (Rate) because water supply is a Twelfth Schedule municipal function. The question whether the tripartite arrangement created two distinct supplies was held not maintainable within the questions raised. DSCL was also held not to be a pure agent under Rule 33, so the contractor-related amounts formed part of the value of supply.
DSCL qualified as a Governmental Authority because it was a government-established special purpose vehicle with 90% or more governmental equity/control and was set up to implement urban local body functions. Its services for the Smart City/ESCO water-supply project to UJS were exempt under Serial No. 4 of Notification No. 12/2017-Central Tax (Rate) because water supply is a Twelfth Schedule municipal function. The question whether the tripartite arrangement created two distinct supplies was held not maintainable within the questions raised. DSCL was also held not to be a pure agent under Rule 33, so the contractor-related amounts formed part of the value of supply.
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