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...
Ratification of resignation acceptance validates separation retrospectively, while withdrawal may be refused through reasoned administrative discretio...
Taxable services or not - mining services - Appellant had been providing taxable services in the state of Jharkhand prior to obtaining registration in the state of Jharkhand or not - It is also observed that surprisingly, certain invoices raised by the Appellant did not contain any address. Therefore, even if for the sake of argument it is accepted that the Appellant was providing services from Odisha, there are no cogent reason to justify the mention of their address in Jharkhand in the invoices while there being no mention of their registered address in Odisha at the same time. - AT
Taxable services or not - mining services - Appellant had been providing taxable services in the state of Jharkhand prior to obtaining registration in the state of Jharkhand or not - It is also observed that surprisingly, certain invoices raised by the Appellant did not contain any address. Therefore, even if for the sake of argument it is accepted that the Appellant was providing services from Odisha, there are no cogent reason to justify the mention of their address in Jharkhand in the invoices while there being no mention of their registered address in Odisha at the same time. - AT
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