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...
Demand of service tax - SEBI - ‘negative list regime’ - demand of tax on the fees collected - We cannot but withhold our ascertainment of the legality of the claim made by the appellant before us. - it is difficult to conceive of any motive in not complying with tax liabilities. There is also no allegation of suppression or misrepresentation by the appellant. - The demand for the period beyond normal limitation, therefore, does not sustain - Consequently, the penalty under section 78 of Finance Act, 1994 is set aside. - AT
Demand of service tax - SEBI - ‘negative list regime’ - demand of tax on the fees collected - We cannot but withhold our ascertainment of the legality of the claim made by the appellant before us. - it is difficult to conceive of any motive in not complying with tax liabilities. There is also no allegation of suppression or misrepresentation by the appellant. - The demand for the period beyond normal limitation, therefore, does not sustain - Consequently, the penalty under section 78 of Finance Act, 1994 is set aside. - AT
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4828 
Join Channel 
