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...
Deduction of service tax from the amount payment (consideration) as per the contract terms - scope of the terms of agreement - the parties did not envisage deduction in the agreed rate from alleged service tax payment. The agreed rate was understood by the parties to be all inclusive and the same would bind the parties. - The respondent have acted illegally, wrongly and malafidely withholding the amount on the alleged ground that service tax is not applicable to the agreed rate.
Deduction of service tax from the amount payment (consideration) as per the contract terms - scope of the terms of agreement - the parties did not envisage deduction in the agreed rate from alleged service tax payment. The agreed rate was understood by the parties to be all inclusive and the same would bind the parties. - The respondent have acted illegally, wrongly and malafidely withholding the amount on the alleged ground that service tax is not applicable to the agreed rate.
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