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 allows the tax revision and restores the AO's assessment under Section 3B of the TNGST Act. The court finds that two separately incorporated companies (hereafter Company A and Company B), although sharing common directors, are distinct legal persons; materials purchased by Company A from other States and used in construction, then transferred to Company B, constitute a transfer of property in goods involved in execution of a works contract and are taxable on the value of goods used. The Appellate Assistant Commissioner and the Tribunal erred in treating the concerns as one and the same merely due to common directorship. The AO's levy under Section 3B is upheld and the revision is allowed.
HC allows the tax revision and restores the AO's assessment under Section 3B of the TNGST Act. The court finds that two separately incorporated companies (hereafter Company A and Company B), although sharing common directors, are distinct legal persons; materials purchased by Company A from other States and used in construction, then transferred to Company B, constitute a transfer of property in goods involved in execution of a works contract and are taxable on the value of goods used. The Appellate Assistant Commissioner and the Tribunal erred in treating the concerns as one and the same merely due to common directorship. The AO's levy under Section 3B is upheld and the revision is allowed.
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