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...
Exemption from tax for supply of selling space for advertisement in print media qualifies as pure service under Entry 3 of Exemption Notification. Supply does not constitute composite supply of goods and services under Entry 3A. Pune and Pimpri Municipal Corporations are local authorities u/s 2(69) of GST Act for Entries 3 and 3A. Content of advertisement for recruitment of medical officers and professors has connection to functions entrusted to panchayats under Article 243G and municipalities under Article 243W of Constitution. Supply of service of selling space for such advertisements relates to functions entrusted under Articles 243G and 243W, covering wide range of activities provided to local authorities. Being pure services to municipal corporations, the supply is exempted under Entry 3 of Notification 12/2017-Central Tax (Rate).
Exemption from tax for supply of selling space for advertisement in print media qualifies as pure service under Entry 3 of Exemption Notification. Supply does not constitute composite supply of goods and services under Entry 3A. Pune and Pimpri Municipal Corporations are local authorities u/s 2(69) of GST Act for Entries 3 and 3A. Content of advertisement for recruitment of medical officers and professors has connection to functions entrusted to panchayats under Article 243G and municipalities under Article 243W of Constitution. Supply of service of selling space for such advertisements relates to functions entrusted under Articles 243G and 243W, covering wide range of activities provided to local authorities. Being pure services to municipal corporations, the supply is exempted under Entry 3 of Notification 12/2017-Central Tax (Rate).
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