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...
Exemption form GST - upfront premium payable towards the services of leasing of the land for industrial purposes - Notification No. 12/2017 Central Tax (Rate) - The applicant argued that the lease met all conditions for exemption under a specific notification. However, WBAAR concluded that SMPK did not qualify as an entity with 20% or more government ownership, a key condition for the exemption. Therefore, the lease service was not considered exempt under the mentioned notification. - AAR
Exemption form GST - upfront premium payable towards the services of leasing of the land for industrial purposes - Notification No. 12/2017 Central Tax (Rate) - The applicant argued that the lease met all conditions for exemption under a specific notification. However, WBAAR concluded that SMPK did not qualify as an entity with 20% or more government ownership, a key condition for the exemption. Therefore, the lease service was not considered exempt under the mentioned notification. - AAR
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