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...
Validity of demand of service tax - The case involved appeals against an order regarding service tax demands and penalties. The Appellate Tribunal addressed multiple issues raised by the parties. Firstly, it ruled that a demand already paid prior to the show cause notice should not have been included, as it fell under section 73(3) and was not excluded by section 73(4). Secondly, it set aside the demand and penalty for non-payment of service tax reflected in ST-3 returns, as the extended period of limitation was not properly invoked. Additionally, it upheld the Commissioner's finding regarding the reversal of a demand under rule 6(3) of the Credit Rules.
Validity of demand of service tax - The case involved appeals against an order regarding service tax demands and penalties. The Appellate Tribunal addressed multiple issues raised by the parties. Firstly, it ruled that a demand already paid prior to the show cause notice should not have been included, as it fell under section 73(3) and was not excluded by section 73(4). Secondly, it set aside the demand and penalty for non-payment of service tax reflected in ST-3 returns, as the extended period of limitation was not properly invoked. Additionally, it upheld the Commissioner's finding regarding the reversal of a demand under rule 6(3) of the Credit Rules.
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