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...
Circular clarifies that insurance companies are not liable to pay GST on salvage/wreck value deducted from claim settlement amount, as salvage remains property of insured. However, if claim settled without salvage deduction, salvage becomes property of insurer who must discharge GST on subsequent supply. For total loss cases where salvage deducted from claim amount as per policy terms, no GST payable by insurer on salvage value as ownership remains with insured. For claims settled at full insured value without salvage deduction, salvage ownership transfers to insurer necessitating GST payment on eventual sale.
Circular clarifies that insurance companies are not liable to pay GST on salvage/wreck value deducted from claim settlement amount, as salvage remains property of insured. However, if claim settled without salvage deduction, salvage becomes property of insurer who must discharge GST on subsequent supply. For total loss cases where salvage deducted from claim amount as per policy terms, no GST payable by insurer on salvage value as ownership remains with insured. For claims settled at full insured value without salvage deduction, salvage ownership transfers to insurer necessitating GST payment on eventual sale.
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