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...
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...
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Transfer-pricing comparability requires functional similarity and reliable current-year segmental data. Bilcare Ltd. was excluded because of diversified operations, unavailable segmental data, and its pharmaceutical packaging profile, which differed from paper-based aseptic packaging for food and drink products. Karur KCP Packaging Ltd. was excluded because it produced kraft paper and polypropylene bags principally for the cement industry, making its products materially dissimilar. Earlier-year segmental data could not support current-year inclusion where relevant data was unavailable. The Tribunal's fact-based comparability findings disclosed neither error nor perversity, so no substantial question of law arose and the Revenue's appeal was dismissed; the separate Revenue appeal issue remained open.
Transfer-pricing comparability requires functional similarity and reliable current-year segmental data. Bilcare Ltd. was excluded because of diversified operations, unavailable segmental data, and its pharmaceutical packaging profile, which differed from paper-based aseptic packaging for food and drink products. Karur KCP Packaging Ltd. was excluded because it produced kraft paper and polypropylene bags principally for the cement industry, making its products materially dissimilar. Earlier-year segmental data could not support current-year inclusion where relevant data was unavailable. The Tribunal's fact-based comparability findings disclosed neither error nor perversity, so no substantial question of law arose and the Revenue's appeal was dismissed; the separate Revenue appeal issue remained open.
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