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 AAR upheld that charges recovered by the applicant from consumers for deposit work (material and erection charges, pro-rata charges, supervision charges, proportionate line charges, registration fees) constitute incidental and ancillary activities to the principal supply of transmission of electricity. Relying on dictionary definitions and prior SC authority recognizing services as incidental when subordinate or appertaining to a primary activity, the AAR found these deposit works necessary for efficient intra-state transmission and thus integrally connected to the applicant's statutory transmission function. Consequentially, such charges qualify for exemption under Entry No. 25A of Notification No.12/2017 as amended by the later notification.
The AAR upheld that charges recovered by the applicant from consumers for deposit work (material and erection charges, pro-rata charges, supervision charges, proportionate line charges, registration fees) constitute incidental and ancillary activities to the principal supply of transmission of electricity. Relying on dictionary definitions and prior SC authority recognizing services as incidental when subordinate or appertaining to a primary activity, the AAR found these deposit works necessary for efficient intra-state transmission and thus integrally connected to the applicant's statutory transmission function. Consequentially, such charges qualify for exemption under Entry No. 25A of Notification No.12/2017 as amended by the later notification.
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