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...
Levy of service tax - re-sale of licensed information technology software - Service Tax was not leviable in respect of the invoices which were issued before 16/05/2008 even for that part of the service which was rendered after 16/05/2008 where the obligation was created before 16/05/2008 - AT
Levy of service tax - re-sale of licensed information technology software - Service Tax was not leviable in respect of the invoices which were issued before 16/05/2008 even for that part of the service which was rendered after 16/05/2008 where the obligation was created before 16/05/2008 - AT
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