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...
Supply of support services to agriculture, forestry, fishing, animal husbandry by applicant is not a composite supply under GST law. Applicant makes distinct supplies to Shell and farmers, not a single supply to one recipient. Supplies to Shell and farmers cannot be clubbed as composite supply per Section 2(30) of CGST/SGST Acts. Applicant obtains carbon credits from farmers to supply to Shell, but does not act as Shell's agent or in joint venture. Shell has no connection with farmers. Carbon credits trading aspect not discussed. Since supply is not composite, question of principal supply is irrelevant. Non-speaking/non-reasoned order violates natural justice.
Supply of support services to agriculture, forestry, fishing, animal husbandry by applicant is not a composite supply under GST law. Applicant makes distinct supplies to Shell and farmers, not a single supply to one recipient. Supplies to Shell and farmers cannot be clubbed as composite supply per Section 2(30) of CGST/SGST Acts. Applicant obtains carbon credits from farmers to supply to Shell, but does not act as Shell's agent or in joint venture. Shell has no connection with farmers. Carbon credits trading aspect not discussed. Since supply is not composite, question of principal supply is irrelevant. Non-speaking/non-reasoned order violates natural justice.
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