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...
The determination is that where the value of materials and cost of execution work for installation of lines are borne by the recipient of service, and the applicant charges only supervision fees, the value of materials and cost of installation shall not be included in the value of supply for determination of taxable value under GST. The applicant is not a supplier of goods and services as per provisions, as the work is undertaken by the customer itself. There is no relationship between the customer and applicant that can be categorized as supplier and recipient, except for the services of supervising the work. The applicant shall be liable to pay GST only on the supervision charges.
The determination is that where the value of materials and cost of execution work for installation of lines are borne by the recipient of service, and the applicant charges only supervision fees, the value of materials and cost of installation shall not be included in the value of supply for determination of taxable value under GST. The applicant is not a supplier of goods and services as per provisions, as the work is undertaken by the customer itself. There is no relationship between the customer and applicant that can be categorized as supplier and recipient, except for the services of supervising the work. The applicant shall be liable to pay GST only on the supervision charges.
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