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...
Exemption of Central Tax for electricity services under Serial no. 25 of notification dated 28th June, 2017 - respondent invoked Section 74 of CGST Act, 2017 based on circular dated 1st March, 2018 - petitioner, a distribution licensee under Electricity Act, 2003, entitled to exemption notification - clarification in circular cannot be treated as clarification of exemption notification u/s 11(1) - circular declared ultra vires to Section 8 and notification no. 12/2017-CT (R) - petitioner made prima facie case, raised jurisdictional issue, entitled to interim protection - directed to participate in proceedings, no final order without court's leave - liberty to mention after affidavits exchange period.
Exemption of Central Tax for electricity services under Serial no. 25 of notification dated 28th June, 2017 - respondent invoked Section 74 of CGST Act, 2017 based on circular dated 1st March, 2018 - petitioner, a distribution licensee under Electricity Act, 2003, entitled to exemption notification - clarification in circular cannot be treated as clarification of exemption notification u/s 11(1) - circular declared ultra vires to Section 8 and notification no. 12/2017-CT (R) - petitioner made prima facie case, raised jurisdictional issue, entitled to interim protection - directed to participate in proceedings, no final order without court's leave - liberty to mention after affidavits exchange period.
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