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...
Department of Revenue issued notification exempting import of services by foreign airlines' Indian establishments from related parties/overseas establishments when made without consideration. Key conditions include: payment of applicable GST on transport services in India, MoCA certification of airline's designation under bilateral air service agreements, and reciprocal tax exemption for Indian airlines in the foreign country. MoCA provided a list of designated foreign airlines operating in Winter 2024-25 schedule and collected feedback from Indian carriers (Air India, IndiGo, Akasa Air) regarding reciprocal treatment. The notification stems from 54th GST Council recommendations and aims to establish tax parity in international aviation services while ensuring compliance with bilateral agreements.
Department of Revenue issued notification exempting import of services by foreign airlines' Indian establishments from related parties/overseas establishments when made without consideration. Key conditions include: payment of applicable GST on transport services in India, MoCA certification of airline's designation under bilateral air service agreements, and reciprocal tax exemption for Indian airlines in the foreign country. MoCA provided a list of designated foreign airlines operating in Winter 2024-25 schedule and collected feedback from Indian carriers (Air India, IndiGo, Akasa Air) regarding reciprocal treatment. The notification stems from 54th GST Council recommendations and aims to establish tax parity in international aviation services while ensuring compliance with bilateral agreements.
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