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...
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Export valuation requires contemporaneous evidence; unrelated invoices cannot prove overvaluation, and dual penalties on firm and partner are impermis...
Tour operator services wholly begun, performed and ended within Jammu and Kashmir were outside the territorial reach of Chapter V of the Finance Act, 1994, because the levy operated only within its territorial limits and the State was excluded from section 64. Planning or booking activity outside the State did not bring the tours into the service tax net when the service was consumed within the excluded territory. The impugned demand was therefore set aside in full, the assessee's appeal was allowed, and the Revenue's appeal failed.
Tour operator services wholly begun, performed and ended within Jammu and Kashmir were outside the territorial reach of Chapter V of the Finance Act, 1994, because the levy operated only within its territorial limits and the State was excluded from section 64. Planning or booking activity outside the State did not bring the tours into the service tax net when the service was consumed within the excluded territory. The impugned demand was therefore set aside in full, the assessee's appeal was allowed, and the Revenue's appeal failed.
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