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...
Demand of service tax on the interest earned from hire purchase finance transactions. - The Tribunal observes that the ownership of the goods remains with the customers, and the Appellant only finances the purchase. There is no clause providing customers an option to purchase the product at the end of payment of all installments. Relying on the Supreme Court's decision, the Tribunal distinguishes between hire purchase agreements and hire purchase finance agreements. - Demand set aside.
Demand of service tax on the interest earned from hire purchase finance transactions. - The Tribunal observes that the ownership of the goods remains with the customers, and the Appellant only finances the purchase. There is no clause providing customers an option to purchase the product at the end of payment of all installments. Relying on the Supreme Court's decision, the Tribunal distinguishes between hire purchase agreements and hire purchase finance agreements. - Demand set aside.
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