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 - Life Insurance Service - Renting of Immovable Property Service or not - On the taxability of life insurance service, the Tribunal determined that the premium collected by the appellant is exempt from service tax as it pertains to sovereign functions. Regarding renting of immovable property service, the Tribunal upheld the levy of service tax based on recent legal precedent. However, penalties for non-payment of service tax on renting of immovable property were dropped due to conflicting opinions on the applicability of service tax during the relevant period.
Levy of service tax - Life Insurance Service - Renting of Immovable Property Service or not - On the taxability of life insurance service, the Tribunal determined that the premium collected by the appellant is exempt from service tax as it pertains to sovereign functions. Regarding renting of immovable property service, the Tribunal upheld the levy of service tax based on recent legal precedent. However, penalties for non-payment of service tax on renting of immovable property were dropped due to conflicting opinions on the applicability of service tax during the relevant period.
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