Handicraft job work receives concessional GST only for registered principals and predominantly handmade goods; commercial resin articles remain taxabl...
Reassessment disclosure requirements permit stated reasons without revealing information sources, but prior-taxation claims require full examination b...
Independent assessment discretion and corroborated electronic evidence determine validity of on-money additions and undisclosed-consideration assessme...
HC determined that the Transfer Pricing Officer (TPO) must first evaluate whether a corporate guarantee constitutes an international transaction under Section 92B before proceeding with transfer pricing adjustments. The Tribunal's broad remittance order lacked specificity on this crucial preliminary issue. The HC remanded the matter to the Assessing Officer (AO) with explicit instructions to first determine if the obligation undertaken through the guarantee qualifies as an international transaction. Only upon affirmative determination should subsequent transfer pricing implications be considered. The scope of examination was narrowed to focus specifically on the characterization of the guarantee obligation within the international transaction framework.
HC determined that the Transfer Pricing Officer (TPO) must first evaluate whether a corporate guarantee constitutes an international transaction under Section 92B before proceeding with transfer pricing adjustments. The Tribunal's broad remittance order lacked specificity on this crucial preliminary issue. The HC remanded the matter to the Assessing Officer (AO) with explicit instructions to first determine if the obligation undertaken through the guarantee qualifies as an international transaction. Only upon affirmative determination should subsequent transfer pricing implications be considered. The scope of examination was narrowed to focus specifically on the characterization of the guarantee obligation within the international transaction framework.
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