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...
Clarification provided that custodial services provided by banks or financial institutions to Foreign Portfolio Investors (FPIs) are not treated as services provided to 'account holder' u/s 13(8)(a) of IGST Act. Such services are not covered u/s 13(8)(a). Place of supply of custodial services to FPIs is to be determined under default provision i.e. sub-section (2) of Section 13 of IGST Act, not u/s 13(8)(a).
Clarification provided that custodial services provided by banks or financial institutions to Foreign Portfolio Investors (FPIs) are not treated as services provided to 'account holder' u/s 13(8)(a) of IGST Act. Such services are not covered u/s 13(8)(a). Place of supply of custodial services to FPIs is to be determined under default provision i.e. sub-section (2) of Section 13 of IGST Act, not u/s 13(8)(a).
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