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...
Liability to pay Goods and Services Tax (GST) for intra-state and interstate delivery of electrical energy. The applicant questioned if they could claim CGST and SGST paid during the procurement of a solar power plant as input tax credit towards their GST liability. The ruling found that since the applicant invoiced only for the supply of electricity without including delivery charges, which are exempt from tax, they were not liable to pay GST on both intra-state and interstate deliveries. Additionally, as their output supplies were tax-exempt, they were not eligible to claim input tax credit on their inward supplies such as the solar power plant under relevant tax provisions.
Liability to pay Goods and Services Tax (GST) for intra-state and interstate delivery of electrical energy. The applicant questioned if they could claim CGST and SGST paid during the procurement of a solar power plant as input tax credit towards their GST liability. The ruling found that since the applicant invoiced only for the supply of electricity without including delivery charges, which are exempt from tax, they were not liable to pay GST on both intra-state and interstate deliveries. Additionally, as their output supplies were tax-exempt, they were not eligible to claim input tax credit on their inward supplies such as the solar power plant under relevant tax provisions.
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