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...
CENVAT Credit - assessee was not registered during the relevant period - They become eligible at the time after taking the registration by the Service Providers and payment of Service Tax. Therefore, the appellant at the most is liable for interest liability from the date the Cenvat Credit taken till the Service Tax paid by the Service Providers, however, for this reason, Cenvat Credit cannot be denied
CENVAT Credit - assessee was not registered during the relevant period - They become eligible at the time after taking the registration by the Service Providers and payment of Service Tax. Therefore, the appellant at the most is liable for interest liability from the date the Cenvat Credit taken till the Service Tax paid by the Service Providers, however, for this reason, Cenvat Credit cannot be denied
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