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...
Liability to pay tax / GST - Validity of Rulings of AAR and AAAR - educational institution or not - The contention of the petitioner, as seen from both the orders challenged here, has neither been considered nor has it been answered specifically by these authorities. - The authorities ought to have considered this contention independently of the activity of MGIMS and in the light of the manner in which the aims and objects of the society is fulfilled by the petitioner-society. - Orders quashed and matter restored before AAR - HC
Liability to pay tax / GST - Validity of Rulings of AAR and AAAR - educational institution or not - The contention of the petitioner, as seen from both the orders challenged here, has neither been considered nor has it been answered specifically by these authorities. - The authorities ought to have considered this contention independently of the activity of MGIMS and in the light of the manner in which the aims and objects of the society is fulfilled by the petitioner-society. - Orders quashed and matter restored before AAR - HC
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