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...
CENVAT Credit - inputs/capital goods - fabrication/ creation/ installation of capital goods - The issue involved in Bharti Airtel is about the credit on Tower parts and pre-fabricated buildings in the case of service provider and as such cannot be applied in the case of credit as inputs used in the manufacture of capital goods which are further used in the manufacture of excisable goods - the appeal stands on merits of the case and that when the appeal survive on merits, other issue like penalty etc. become irrelevant. - AT
CENVAT Credit - inputs/capital goods - fabrication/ creation/ installation of capital goods - The issue involved in Bharti Airtel is about the credit on Tower parts and pre-fabricated buildings in the case of service provider and as such cannot be applied in the case of credit as inputs used in the manufacture of capital goods which are further used in the manufacture of excisable goods - the appeal stands on merits of the case and that when the appeal survive on merits, other issue like penalty etc. become irrelevant. - AT
Note: It is a system-generated summary and is for quick reference only.
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