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...
CESTAT New Delhi held that providing Corporate Guarantee without consideration is not taxable u/s 66B of Finance Act, 1994 as it lacks 'provider' and 'consideration' elements. Profit/markup is taxable under service tax based on precedent cases like M/s Tiger Logistics (India) Ltd. The tribunal upheld the order, dismissing the revenue appeal.
CESTAT New Delhi held that providing Corporate Guarantee without consideration is not taxable u/s 66B of Finance Act, 1994 as it lacks 'provider' and 'consideration' elements. Profit/markup is taxable under service tax based on precedent cases like M/s Tiger Logistics (India) Ltd. The tribunal upheld the order, dismissing the revenue appeal.
Note: It is a system-generated summary and is for quick reference only.