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...
CESTAT adjudicated a service tax dispute involving a business correspondent's tax liability. The tribunal held that the appellant was eligible for exemption under entry 29(g) for services provided to rural banking branches during 01.04.2015 to 30.06.2017. No short payment of service tax was found for services to Rajcomp Info Services Ltd. The extended period of limitation was deemed non-invocable, and most penalties were set aside, with only a Rs.10,000 penalty under Section 77(2) upheld for non-filing of service tax returns. The tribunal effectively reduced the original tax demand, finding the appellant's actions were in good faith and not intentionally evasive.
CESTAT adjudicated a service tax dispute involving a business correspondent's tax liability. The tribunal held that the appellant was eligible for exemption under entry 29(g) for services provided to rural banking branches during 01.04.2015 to 30.06.2017. No short payment of service tax was found for services to Rajcomp Info Services Ltd. The extended period of limitation was deemed non-invocable, and most penalties were set aside, with only a Rs.10,000 penalty under Section 77(2) upheld for non-filing of service tax returns. The tribunal effectively reduced the original tax demand, finding the appellant's actions were in good faith and not intentionally evasive.
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