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...
Classification of services - Whether providing space on roof for transportation of parcels/goods can be considered as "Business Support Service" by the Department? - The Tribunal examined the agreement terms and found that the primary activity of the appellant was to provide open space for storage of parcels at bus depots. The Tribunal noted that the appellant charged a license fee for this space, and the responsibility for managing the parcels rested with the company. It was held that this activity did not qualify as "Business Support Service."
Classification of services - Whether providing space on roof for transportation of parcels/goods can be considered as "Business Support Service" by the Department? - The Tribunal examined the agreement terms and found that the primary activity of the appellant was to provide open space for storage of parcels at bus depots. The Tribunal noted that the appellant charged a license fee for this space, and the responsibility for managing the parcels rested with the company. It was held that this activity did not qualify as "Business Support Service."
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