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 - Franchise service (reverse charge) - Revenue Sharing Agreement - Instead for every student enrolled in a course, Centennial College, Canada gets a specified amount as a share of the fees. - The tribunal held that the agreement between the appellant and Centennial College, Canada, was determined to be a typical revenue sharing model rather than a franchise service. Therefore, it did not fall within the ambit of taxable franchise services under the reverse charge mechanism.
Demand of service tax - Franchise service (reverse charge) - Revenue Sharing Agreement - Instead for every student enrolled in a course, Centennial College, Canada gets a specified amount as a share of the fees. - The tribunal held that the agreement between the appellant and Centennial College, Canada, was determined to be a typical revenue sharing model rather than a franchise service. Therefore, it did not fall within the ambit of taxable franchise services under the reverse charge mechanism.
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