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...
Classification of services - management and business consultant service - The tribunal held that the activity of disbursal of wages to the unskilled rural labours as a measure of employment generation under Mahatma Gandhi National Rural Employment Guarantee Act (MGNREGA), does not cover under “Management and Business Consultant” Services. Therefore, for the period prior to 01.07.2012, the appellants are not liable to pay service tax. - Merely because, there was an agreement and in terms of the agreement, the service tax was inclusive which is to be borne to the appellants, no demand of service tax can be sustained.
Classification of services - management and business consultant service - The tribunal held that the activity of disbursal of wages to the unskilled rural labours as a measure of employment generation under Mahatma Gandhi National Rural Employment Guarantee Act (MGNREGA), does not cover under “Management and Business Consultant” Services. Therefore, for the period prior to 01.07.2012, the appellants are not liable to pay service tax. - Merely because, there was an agreement and in terms of the agreement, the service tax was inclusive which is to be borne to the appellants, no demand of service tax can be sustained.
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