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...
Services provided to a government entity under Jal Jeevan Mission classified under SAC code 998399. Services to Maharashtra Jeevan Pradhikaran for government functions are taxable at 18%. MJP's setup is lawful as a government-owned body. Exemption applies for services provided before 31-12-2021 under entry No. 3 of Notification No 12/2017. Services after 01-01-2022 not exempt as "Government Authority" omitted from the entry. AAR clarified the classification and tax treatment of the services.
Services provided to a government entity under Jal Jeevan Mission classified under SAC code 998399. Services to Maharashtra Jeevan Pradhikaran for government functions are taxable at 18%. MJP's setup is lawful as a government-owned body. Exemption applies for services provided before 31-12-2021 under entry No. 3 of Notification No 12/2017. Services after 01-01-2022 not exempt as "Government Authority" omitted from the entry. AAR clarified the classification and tax treatment of the services.
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