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...
The HC allowed the petition, holding that the impugned services qualify as exports rather than intermediary supplies for GST purposes. The court concluded the petitioner performed services directly for a single overseas contracting party under a specific contractual arrangement, and absent a tripartite relationship the statutory definition of "intermediary" is not satisfied. Applying the reasoning of co-ordinate appellate and higher judicial authorities, the HC held that the place of provision lies outside the taxable territory and the supply constitutes export of services. Consequently, the respondents' contrary classification was set aside and the petitioner's treatment as an exporter was upheld.
The HC allowed the petition, holding that the impugned services qualify as exports rather than intermediary supplies for GST purposes. The court concluded the petitioner performed services directly for a single overseas contracting party under a specific contractual arrangement, and absent a tripartite relationship the statutory definition of "intermediary" is not satisfied. Applying the reasoning of co-ordinate appellate and higher judicial authorities, the HC held that the place of provision lies outside the taxable territory and the supply constitutes export of services. Consequently, the respondents' contrary classification was set aside and the petitioner's treatment as an exporter was upheld.
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