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 CENVAT Credit - services related to Information Technology (ITSS) - The appellate tribunal analyzed submissions regarding the eligibility for refund on ITSS, the denial of CENVAT credit, denial of credit for service tax paid on generators, and discrepancies between CENVAT records and ST-3 returns. The Tribunal found that while the appellant demonstrated independence from M/s Agilent Technologies (Singapore), they failed to provide evidence of valid orders for ITSS services, leading to the denial of the refund claim. However, they ruled in favor of the appellant regarding the denial of CENVAT credit, credit for service tax paid on generators, and discrepancies between records, remanding these matters for further verification and consideration by the Original Authority.
Refund of CENVAT Credit - services related to Information Technology (ITSS) - The appellate tribunal analyzed submissions regarding the eligibility for refund on ITSS, the denial of CENVAT credit, denial of credit for service tax paid on generators, and discrepancies between CENVAT records and ST-3 returns. The Tribunal found that while the appellant demonstrated independence from M/s Agilent Technologies (Singapore), they failed to provide evidence of valid orders for ITSS services, leading to the denial of the refund claim. However, they ruled in favor of the appellant regarding the denial of CENVAT credit, credit for service tax paid on generators, and discrepancies between records, remanding these matters for further verification and consideration by the Original Authority.
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