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...
Levy of service tax - clearing and forwarding agent service or not - the activity carried out by the appellant was not that of the clearing and forwarding agent as the appellant was not physically handling the goods on behalf of its client - though the Tribunal had earlier concluded that the appellant was liable to pay the service tax as that of a clearing and forwarding agent nothing precluded the Tribunal from revisiting the issue afresh while passing the impugned Final Order - HC
Levy of service tax - clearing and forwarding agent service or not - the activity carried out by the appellant was not that of the clearing and forwarding agent as the appellant was not physically handling the goods on behalf of its client - though the Tribunal had earlier concluded that the appellant was liable to pay the service tax as that of a clearing and forwarding agent nothing precluded the Tribunal from revisiting the issue afresh while passing the impugned Final Order - HC
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