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...
Input Credit - separate contracts for supply of transformer as well as erection and commissioning - When the value of both the activity is separately shown, both the activities cannot be clubbed to make it taxable under the Works contract composition scheme - the revenue has nowhere disputed the payment of central excise duty on transformer and therefore once excise duty payment is made, the Appellant is eligible for availing credit
Input Credit - separate contracts for supply of transformer as well as erection and commissioning - When the value of both the activity is separately shown, both the activities cannot be clubbed to make it taxable under the Works contract composition scheme - the revenue has nowhere disputed the payment of central excise duty on transformer and therefore once excise duty payment is made, the Appellant is eligible for availing credit
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