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...
Levy of service tax - remuneration paid by a company to the Managing Director and the whole time Executive Director - whether such income is a salary income or otherwise the same can be established on the basis of employment conditions for employment of directors as company’s employees. In the entire proceedings the appellant have not produced the appointment order of the directors as employees containing the terms and conditions of the employment - Matter remanded back - AT
Levy of service tax - remuneration paid by a company to the Managing Director and the whole time Executive Director - whether such income is a salary income or otherwise the same can be established on the basis of employment conditions for employment of directors as company’s employees. In the entire proceedings the appellant have not produced the appointment order of the directors as employees containing the terms and conditions of the employment - Matter remanded back - AT
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