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...
CENVAT Credit - exempt service or not - amount of interest received by the appellant on the delayed payment of the amount of consideration received from the sale of flats/villas/shops - The Tribunal observed that the interest received is akin to liquidated damages or compensation and does not constitute an exempted service. Therefore, the appellant is not liable for reversal of Cenvat credit based on this interest. The appellant did not perform any service to receive the interest; it was merely a deterrent for delayed payments, thus not requiring reversal of Cenvat credit.
CENVAT Credit - exempt service or not - amount of interest received by the appellant on the delayed payment of the amount of consideration received from the sale of flats/villas/shops - The Tribunal observed that the interest received is akin to liquidated damages or compensation and does not constitute an exempted service. Therefore, the appellant is not liable for reversal of Cenvat credit based on this interest. The appellant did not perform any service to receive the interest; it was merely a deterrent for delayed payments, thus not requiring reversal of Cenvat credit.
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