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...
HC dismissed the writ petition challenging service tax adjudication against municipal corporation services. Despite arguments regarding exemption under Notification No. 25/2012-ST, the court found the petitioners' request for a common adjudicator as an afterthought. The original adjudication orders were set aside for procedural irregularities and remanded for fresh consideration, while maintaining the individual nature of each petitioner's case. The court emphasized that the KMC's exemption claim remains subject to detailed scrutiny and has not been automatically accepted.
HC dismissed the writ petition challenging service tax adjudication against municipal corporation services. Despite arguments regarding exemption under Notification No. 25/2012-ST, the court found the petitioners' request for a common adjudicator as an afterthought. The original adjudication orders were set aside for procedural irregularities and remanded for fresh consideration, while maintaining the individual nature of each petitioner's case. The court emphasized that the KMC's exemption claim remains subject to detailed scrutiny and has not been automatically accepted.
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