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...
Scope of supply - Exemption from GST - services provided by Executive Council of Insurers (ECOI) and ombudsman officers to the aggrieved persons who have grievances against insurance companies/insurers - In fact, it is found that the Insurers, being the persons against whom there is a grievance, are also interested in solving the relevant issues and in this context, it is seen that by deciding on the complaints of the aggrieved persons, the insurance company being party to such disputes are also availing the services of the applicant/Ombudsman. Hence, the impugned activity undertaken by the applicant amounts to 'supply of services'. - the activities of the applicant are not exempt under the said notification - AAR
Scope of supply - Exemption from GST - services provided by Executive Council of Insurers (ECOI) and ombudsman officers to the aggrieved persons who have grievances against insurance companies/insurers - In fact, it is found that the Insurers, being the persons against whom there is a grievance, are also interested in solving the relevant issues and in this context, it is seen that by deciding on the complaints of the aggrieved persons, the insurance company being party to such disputes are also availing the services of the applicant/Ombudsman. Hence, the impugned activity undertaken by the applicant amounts to 'supply of services'. - the activities of the applicant are not exempt under the said notification - AAR
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