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...
Non-discharge of service tax - extended period invoked, service tax demanded - penalties imposed u/ss 77 and 78 of Finance Act, 1994 - appellant providing taxable maintenance, repair, manpower recruitment and supply services - appellant computed and paid service tax due - lack of knowledge and status as petty contractor pleaded - authorities imposed heavy penalties despite appellant's compliance before adjudication - undisputed findings regarding appellant's status and compliance - no justification for not considering Section 80 benefit and waiving penalties - fit case for waiving penalties u/ss 77 and 78 in terms of Section 80 - appeal partly allowed, setting aside penalties imposed on appellant.
Non-discharge of service tax - extended period invoked, service tax demanded - penalties imposed u/ss 77 and 78 of Finance Act, 1994 - appellant providing taxable maintenance, repair, manpower recruitment and supply services - appellant computed and paid service tax due - lack of knowledge and status as petty contractor pleaded - authorities imposed heavy penalties despite appellant's compliance before adjudication - undisputed findings regarding appellant's status and compliance - no justification for not considering Section 80 benefit and waiving penalties - fit case for waiving penalties u/ss 77 and 78 in terms of Section 80 - appeal partly allowed, setting aside penalties imposed on appellant.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4798
Join Channel
TaxTMI 
