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...
Refund of service tax paid as sub-contractor - Rejection on the ground that Section 102 exempts services rendered to a Government, a local Authority or a Government Authority and does not exempt services rendered to a private company which in this case is M/s NBCC - The Tribunal interpreted Section 102 of the Finance Act, 1994, and held that the exemption applied to services provided to government entities, including educational institutions, regardless of whether the services were rendered directly or through subcontractors. The court emphasized that the nature of the service and the ultimate beneficiary, i.e., the government entity, determined the applicability of the exemption. - The CESTAT ruled in favor of the subcontractor, holding that they were entitled to the refund.
Refund of service tax paid as sub-contractor - Rejection on the ground that Section 102 exempts services rendered to a Government, a local Authority or a Government Authority and does not exempt services rendered to a private company which in this case is M/s NBCC - The Tribunal interpreted Section 102 of the Finance Act, 1994, and held that the exemption applied to services provided to government entities, including educational institutions, regardless of whether the services were rendered directly or through subcontractors. The court emphasized that the nature of the service and the ultimate beneficiary, i.e., the government entity, determined the applicability of the exemption. - The CESTAT ruled in favor of the subcontractor, holding that they were entitled to the refund.
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