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...
Pure service - Benefit of exemption from GST - Governmental Entity or not - Renting of immovable Property Services i.e. 'Pure Service' provided by the applicant to PCSCL, a Government Entity, are not by way of any activity in relation to functions entrusted to a Municipality under article 243W of the Constitution or entrusted to a Panchayat under Article 243 G of the constitution and therefore, the impugned service supplied by the applicant is not exempt - taxable @18% of GST - TDS liable to be deducted - AAR
Pure service - Benefit of exemption from GST - Governmental Entity or not - Renting of immovable Property Services i.e. 'Pure Service' provided by the applicant to PCSCL, a Government Entity, are not by way of any activity in relation to functions entrusted to a Municipality under article 243W of the Constitution or entrusted to a Panchayat under Article 243 G of the constitution and therefore, the impugned service supplied by the applicant is not exempt - taxable @18% of GST - TDS liable to be deducted - AAR
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