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 - business support service - making facility to the customers to book online tickets of movies and other shows - The Appellate Tribunal found that the appellant did not receive any consideration from the card companies for providing business support services. Since no invoices were raised by the appellant against the services rendered to the card companies, the Tribunal concluded that no consideration was received. This aligned with the principle that consideration must be present for a service to be taxed. The Tribunal observed that the appellant had not retained any amount received from the card companies. Instead, these amounts were intended to be paid to cinema houses. Therefore, the Tribunal set aside the impugned order and allowed the appeal.
Levy of service tax - business support service - making facility to the customers to book online tickets of movies and other shows - The Appellate Tribunal found that the appellant did not receive any consideration from the card companies for providing business support services. Since no invoices were raised by the appellant against the services rendered to the card companies, the Tribunal concluded that no consideration was received. This aligned with the principle that consideration must be present for a service to be taxed. The Tribunal observed that the appellant had not retained any amount received from the card companies. Instead, these amounts were intended to be paid to cinema houses. Therefore, the Tribunal set aside the impugned order and allowed the appeal.
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