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...
Liability to pay Service Tax when the main contractor has already paid - The Tribunal cited a circular stating sub-contractors are liable to pay Service Tax separately. However, they ruled the extended limitation period couldn't be invoked due to ambiguity during the relevant period. Regarding the normal limitation period, they upheld the demand for October 2010 to March 2011. They rejected the appellant's argument based on a Supreme Court case and noted that the demand for this period wasn't dead. Ultimately, they confirmed the demand for the normal period but set aside the extended period demand.
Liability to pay Service Tax when the main contractor has already paid - The Tribunal cited a circular stating sub-contractors are liable to pay Service Tax separately. However, they ruled the extended limitation period couldn't be invoked due to ambiguity during the relevant period. Regarding the normal limitation period, they upheld the demand for October 2010 to March 2011. They rejected the appellant's argument based on a Supreme Court case and noted that the demand for this period wasn't dead. Ultimately, they confirmed the demand for the normal period but set aside the extended period demand.
Note: It is a system-generated summary and is for quick reference only.