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...
Composite supply involving works contract services provided to local authority not exempt under GST. Entry 3B of Notification No. 13/2017-CT(Rate) exempting services to government authority not applicable as applicant providing works contract services with supply of goods exceeding 25% value. Entries 3, 3A and 3B interlinked, exemption limited to pure services or composite supply with goods value not exceeding 25%. Applicant providing sewerage system works to Municipal Corporation, a local authority, attracts GST as per entries 3 and 3A covering services to local authorities. Entry 3B inapplicable as works contract with predominant supply of goods.
Composite supply involving works contract services provided to local authority not exempt under GST. Entry 3B of Notification No. 13/2017-CT(Rate) exempting services to government authority not applicable as applicant providing works contract services with supply of goods exceeding 25% value. Entries 3, 3A and 3B interlinked, exemption limited to pure services or composite supply with goods value not exceeding 25%. Applicant providing sewerage system works to Municipal Corporation, a local authority, attracts GST as per entries 3 and 3A covering services to local authorities. Entry 3B inapplicable as works contract with predominant supply of goods.
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