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...
Pure services provided by the applicant for survey, design, drawing, estimates, and comprehensive plan preparation related to water supply schemes qualify as services supplied to the State Government under the Atal Mission for Rejuvenation and Urban Transformation (AMRUT) project. These services relate to functions entrusted to Panchayats under Article 243G or Municipalities under Article 243W of the Constitution, such as drinking water supply for domestic, industrial, and commercial purposes listed in the Eleventh and Twelfth Schedules. Consequently, the applicant's services satisfy the condition specified in serial number 3 of the exemption notification regarding the status of the recipient and the nature of services provided.
Pure services provided by the applicant for survey, design, drawing, estimates, and comprehensive plan preparation related to water supply schemes qualify as services supplied to the State Government under the Atal Mission for Rejuvenation and Urban Transformation (AMRUT) project. These services relate to functions entrusted to Panchayats under Article 243G or Municipalities under Article 243W of the Constitution, such as drinking water supply for domestic, industrial, and commercial purposes listed in the Eleventh and Twelfth Schedules. Consequently, the applicant's services satisfy the condition specified in serial number 3 of the exemption notification regarding the status of the recipient and the nature of services provided.
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