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 provided on applicability of GST: 1) Leasing of motor vehicles without operators not included in 'same line of business' for passenger transport services, attracting higher GST rate. 2) Electricity charges reimbursed by lessees/occupants to real estate companies/malls taxable as part of composite supply of renting/maintenance services, except when charged on pure agent basis. 3) Job work for processing barley into malted barley attracts 5% GST as food product, irrespective of end-use. 4) District Mineral Foundation Trusts set up by state governments are governmental authorities eligible for GST exemptions. 5) Horticulture/landscaping services provided to CPWD for public parks/areas exempt from GST under specified notification.
Clarifications provided on applicability of GST: 1) Leasing of motor vehicles without operators not included in 'same line of business' for passenger transport services, attracting higher GST rate. 2) Electricity charges reimbursed by lessees/occupants to real estate companies/malls taxable as part of composite supply of renting/maintenance services, except when charged on pure agent basis. 3) Job work for processing barley into malted barley attracts 5% GST as food product, irrespective of end-use. 4) District Mineral Foundation Trusts set up by state governments are governmental authorities eligible for GST exemptions. 5) Horticulture/landscaping services provided to CPWD for public parks/areas exempt from GST under specified notification.
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