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 - water charges paid - transfer of right to use the water by the Government to the appellant - Deemed sale - Since the agreement was for water supply, not services, the Tribunal found that service tax was not applicable to the water charges paid. - Considering the agreement's pre-2016 date, the Tribunal held that any services provided should be governed by pre-2016 provisions, exempting the appellant from tax liability. - Further, the Tribunal agreed with the appellant's argument that the water supply constituted the supply of goods, not services, aligning with the Finance Act's definition.
Levy of service tax - water charges paid - transfer of right to use the water by the Government to the appellant - Deemed sale - Since the agreement was for water supply, not services, the Tribunal found that service tax was not applicable to the water charges paid. - Considering the agreement's pre-2016 date, the Tribunal held that any services provided should be governed by pre-2016 provisions, exempting the appellant from tax liability. - Further, the Tribunal agreed with the appellant's argument that the water supply constituted the supply of goods, not services, aligning with the Finance Act's definition.
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