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...
Rejection of refund claim - GTA Service - time limitation - The tribunal reaffirmed the previous tribunal orders that transportation of coal within and outside mining areas does not constitute GTA service due to the absence of consignment notes. Therefore, the appellant is not liable to pay service tax under RCM for GTA service. - The tribunal found that the refund claim was filed within the prescribed time limit, as it was based on the final order of the tribunal dated 13.08.2014, and thus, was not barred by time.
Rejection of refund claim - GTA Service - time limitation - The tribunal reaffirmed the previous tribunal orders that transportation of coal within and outside mining areas does not constitute GTA service due to the absence of consignment notes. Therefore, the appellant is not liable to pay service tax under RCM for GTA service. - The tribunal found that the refund claim was filed within the prescribed time limit, as it was based on the final order of the tribunal dated 13.08.2014, and thus, was not barred by time.
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