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...
AAAR dismissed the appeal and upheld denial of exemption under entry 3 of Notification No. 12/2017, holding that the appellant's lease of building property to a government department for use as college hostels constitutes a pure supply of immovable property and is not made "in relation to" the statutory functions of panchayats or similar authorities. The authority determined that the phrase "in relation to" must be construed in its legal sense-concerning or pertaining to the statutory function-and the appellant's services were not sufficiently connected to those functions. Accordingly, the claimed exemption was rejected and the appeal was dismissed.
AAAR dismissed the appeal and upheld denial of exemption under entry 3 of Notification No. 12/2017, holding that the appellant's lease of building property to a government department for use as college hostels constitutes a pure supply of immovable property and is not made "in relation to" the statutory functions of panchayats or similar authorities. The authority determined that the phrase "in relation to" must be construed in its legal sense-concerning or pertaining to the statutory function-and the appellant's services were not sufficiently connected to those functions. Accordingly, the claimed exemption was rejected and the appeal was dismissed.
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