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...
CENVAT Credit - input services - erection and commissioning of machines carried out in China and Italy based on invoices / debit notes raised by M/s.Voltas Ltd., Coimbatore - The department contested the eligibility, arguing that these services were not directly related to the manufacture of the appellant's finished products. However, the Appellate Tribunal ruled in favor of the appellant, citing the broad definition of "input services" during the relevant period, which encompassed activities relating to business. Additionally, they acknowledged the necessity of the outsourced services for the operation of the exported machines, thereby allowing the appellant's claim for credit.
CENVAT Credit - input services - erection and commissioning of machines carried out in China and Italy based on invoices / debit notes raised by M/s.Voltas Ltd., Coimbatore - The department contested the eligibility, arguing that these services were not directly related to the manufacture of the appellant's finished products. However, the Appellate Tribunal ruled in favor of the appellant, citing the broad definition of "input services" during the relevant period, which encompassed activities relating to business. Additionally, they acknowledged the necessity of the outsourced services for the operation of the exported machines, thereby allowing the appellant's claim for credit.
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