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 - Appellant claimed that NIXI is not the ISP (internet service provider) - a single transaction of providing peering cannot be split into two transactions, nor is it permissible to artificially vivisect a composite indivisible commercial transaction and examine one part for taxability purposes. - AT
Levy of service tax - Appellant claimed that NIXI is not the ISP (internet service provider) - a single transaction of providing peering cannot be split into two transactions, nor is it permissible to artificially vivisect a composite indivisible commercial transaction and examine one part for taxability purposes. - AT
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