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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...
Controlled transactions cannot be used as CUP comparables for brand royalty, so that adjustment was deleted. ECB interest benchmarking accepted RBI approval as a relevant contemporaneous benchmark and deleted the adjustment. AMP expenditure was not treated as an international transaction without tangible evidence of an arrangement. Depreciation on 3G spectrum rights, DoT subscriber verification payments, prepaid distributor discount and IBM hardware lease rentals were allowed, while liabilities written back were sustained and asset restoration cost was allowed as revenue expenditure. Annual licence fee remained capital in nature with only recomputation of amortisation under the telecom licence regime, and WPC royalty charges were also allowed.
Controlled transactions cannot be used as CUP comparables for brand royalty, so that adjustment was deleted. ECB interest benchmarking accepted RBI approval as a relevant contemporaneous benchmark and deleted the adjustment. AMP expenditure was not treated as an international transaction without tangible evidence of an arrangement. Depreciation on 3G spectrum rights, DoT subscriber verification payments, prepaid distributor discount and IBM hardware lease rentals were allowed, while liabilities written back were sustained and asset restoration cost was allowed as revenue expenditure. Annual licence fee remained capital in nature with only recomputation of amortisation under the telecom licence regime, and WPC royalty charges were also allowed.
Note: It is a system-generated summary and is for quick reference only.
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