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...
Levy of service tax - Export of services or not - amount has been received in Indian Currency - The tribunal concluded that the service provided by the appellant qualified as an export of service. It emphasized that the appellant acted as an agent for the foreign exporter and that the contract between the parties clearly specified commission rates in US dollars. Despite receiving payment in Indian Rupees, the tribunal deemed the service to be an export as it fulfilled the conditions under Rule 3(2)(b) of the Export of Service Rules, 2005.
Levy of service tax - Export of services or not - amount has been received in Indian Currency - The tribunal concluded that the service provided by the appellant qualified as an export of service. It emphasized that the appellant acted as an agent for the foreign exporter and that the contract between the parties clearly specified commission rates in US dollars. Despite receiving payment in Indian Rupees, the tribunal deemed the service to be an export as it fulfilled the conditions under Rule 3(2)(b) of the Export of Service Rules, 2005.
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