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...
Clarifications issued on applicability of GST Reverse Charge Mechanism (RCM) for services provided by directors to companies and taxability of food/beverages supplied in cinema halls. Services by directors in personal capacity like renting immovable property are not subject to RCM. Only services rendered in director's official capacity attract RCM. Supply of food/beverages in cinema halls qualifies as restaurant service taxable at 5% GST, except when bundled with cinema exhibition as composite supply, where the bundled rate applies. Difficulties in implementation to be brought to notice of Pr. Commissioner, Trade and Tax.
Clarifications issued on applicability of GST Reverse Charge Mechanism (RCM) for services provided by directors to companies and taxability of food/beverages supplied in cinema halls. Services by directors in personal capacity like renting immovable property are not subject to RCM. Only services rendered in director's official capacity attract RCM. Supply of food/beverages in cinema halls qualifies as restaurant service taxable at 5% GST, except when bundled with cinema exhibition as composite supply, where the bundled rate applies. Difficulties in implementation to be brought to notice of Pr. Commissioner, Trade and Tax.
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