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...
Import of services - certain reimbursements made to the foreign entities for the services received under Reverse Charge Mechanism - networking charges and technical services - The appellant argued that reimbursements for services performed outside India should not be taxed. The Tribunal agreed, referencing the Intercontinental Consultants & Technocrats case, which held that only the consideration for the taxable service should be valued and assessed, not additional expenses.
Import of services - certain reimbursements made to the foreign entities for the services received under Reverse Charge Mechanism - networking charges and technical services - The appellant argued that reimbursements for services performed outside India should not be taxed. The Tribunal agreed, referencing the Intercontinental Consultants & Technocrats case, which held that only the consideration for the taxable service should be valued and assessed, not additional expenses.
Note: It is a system-generated summary and is for quick reference only.