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...
Extended limitation was unavailable because the disputes arose from interpretational issues, the contracts were public projects reflected in the records, and there was no cogent material showing suppression or intent to evade; demands beyond the normal period were therefore time-barred. Works contract exemption was allowed for construction of the FCI food grain godown and the Integrated Farmers' Market Complex, as both were public infrastructure projects falling within the relevant exemption entries and not shown to be predominantly commercial. The mobilization advance demand failed because it was a recoverable, interest-bearing contractual accommodation and was also time-barred. Statutory trade licence fees were treated as a regulatory levy, not taxable consideration, and the penalty for suppression was set aside. The appeal succeeded in full.
Extended limitation was unavailable because the disputes arose from interpretational issues, the contracts were public projects reflected in the records, and there was no cogent material showing suppression or intent to evade; demands beyond the normal period were therefore time-barred. Works contract exemption was allowed for construction of the FCI food grain godown and the Integrated Farmers' Market Complex, as both were public infrastructure projects falling within the relevant exemption entries and not shown to be predominantly commercial. The mobilization advance demand failed because it was a recoverable, interest-bearing contractual accommodation and was also time-barred. Statutory trade licence fees were treated as a regulatory levy, not taxable consideration, and the penalty for suppression was set aside. The appeal succeeded in full.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4796
Join Channel
TaxTMI 
