Online bond platforms may offer overseas-regulated products and tax-specific bonds subject to disclosures, compliance safeguards and revised complianc...
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...
Transfer-pricing method selection between the Comparable Uncontrolled Price method and the Transactional Net Margin Method is primarily a fact-based benchmarking issue. The Tribunal's acceptance of TNMM as the most appropriate method was treated as sustainable where it was not perverse or contrary to the record. Mere disagreement over the appropriate method does not create a substantial question of law under section 260A unless the selected method contravenes prescribed rules. Differences between associated-enterprise and non-associated-enterprise transactions were also considered within the benchmarking analysis. The tax appeals were dismissed because the transfer-pricing questions raised no substantial question of law.
Transfer-pricing method selection between the Comparable Uncontrolled Price method and the Transactional Net Margin Method is primarily a fact-based benchmarking issue. The Tribunal's acceptance of TNMM as the most appropriate method was treated as sustainable where it was not perverse or contrary to the record. Mere disagreement over the appropriate method does not create a substantial question of law under section 260A unless the selected method contravenes prescribed rules. Differences between associated-enterprise and non-associated-enterprise transactions were also considered within the benchmarking analysis. The tax appeals were dismissed because the transfer-pricing questions raised no substantial question of law.
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