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 affirmed the appellate authority's determination and dismissed the departmental appeal, holding that input tax credit (ITC) on capital goods comprising wires, cables and electrical equipment used to connect the DISCOM power supply to the respondent's factory is admissible. The Authority found no legally tenable ground in the Revenue's challenge that such items are excluded as 'plant and machinery' under section 17(5) or that section 18(6) procedures were infringed; the Revenue's contention of subsequent transfer to the transmission utility was unsubstantiated. In light of Board clarifications treating analogous infrastructure items as eligible, the GAAR findings were upheld and the appeal by the Assistant Commissioner was rejected.
AAAR affirmed the appellate authority's determination and dismissed the departmental appeal, holding that input tax credit (ITC) on capital goods comprising wires, cables and electrical equipment used to connect the DISCOM power supply to the respondent's factory is admissible. The Authority found no legally tenable ground in the Revenue's challenge that such items are excluded as 'plant and machinery' under section 17(5) or that section 18(6) procedures were infringed; the Revenue's contention of subsequent transfer to the transmission utility was unsubstantiated. In light of Board clarifications treating analogous infrastructure items as eligible, the GAAR findings were upheld and the appeal by the Assistant Commissioner was rejected.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4796
Join Channel
TaxTMI 
