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...
Ineligibility for claiming ITC on inward supplies of goods or services used for construction on account of own use - The appellant contested the restriction on ITC for immovable property construction, arguing it should apply only to capitalized expenses. The respondent countered that the restriction applies regardless of capitalization. The Appellate Authority (AAAR) affirmed that the restriction applies to all construction expenses, regardless of capitalization, concluding that ITC for such construction is not available.
Ineligibility for claiming ITC on inward supplies of goods or services used for construction on account of own use - The appellant contested the restriction on ITC for immovable property construction, arguing it should apply only to capitalized expenses. The respondent countered that the restriction applies regardless of capitalization. The Appellate Authority (AAAR) affirmed that the restriction applies to all construction expenses, regardless of capitalization, concluding that ITC for such construction is not available.
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