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...
Residential staff quarters built for Government departments and agencies were treated as intended for personal use, so the demand on those contracts remained dropped. Services for GETCO and other non-commercial Government works were also sustained as non-taxable, including transmission and distribution of electricity works covered by exemption principles. By contrast, construction services for APMC were held taxable for the pre-negative list period because APMC renting or allotting space is commercial in nature under Supreme Court precedent. The extended period was upheld due to non-registration, non-filing, non-payment and suppression, while recomputation had to allow the works contract composition scheme and cum-tax benefit, with penalty to follow the revised demand.
Residential staff quarters built for Government departments and agencies were treated as intended for personal use, so the demand on those contracts remained dropped. Services for GETCO and other non-commercial Government works were also sustained as non-taxable, including transmission and distribution of electricity works covered by exemption principles. By contrast, construction services for APMC were held taxable for the pre-negative list period because APMC renting or allotting space is commercial in nature under Supreme Court precedent. The extended period was upheld due to non-registration, non-filing, non-payment and suppression, while recomputation had to allow the works contract composition scheme and cum-tax benefit, with penalty to follow the revised demand.
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