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...
GTA - reverse charge - The appellant is one of the categories specified for tax liability on reverse-charge basis. The freight is borne by the appellant. Though the arrangement is such that M/s NTPC imported the goods as per the contract, the appellant is in-charge of reaching the goods at site office and, thereafter, for further work - appellant liable to pay service tax. - AT
GTA - reverse charge - The appellant is one of the categories specified for tax liability on reverse-charge basis. The freight is borne by the appellant. Though the arrangement is such that M/s NTPC imported the goods as per the contract, the appellant is in-charge of reaching the goods at site office and, thereafter, for further work - appellant liable to pay service tax. - AT
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