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...
Battery energy storage systems (BESS) are characterised as storage facilities that convert electrical energy to chemical energy and back, and therefore are not generation, transmission or distribution utilities; accordingly, exemption notifications for generation/transmission/distribution do not apply, whether BESS is standalone or co located. The activity of developing and operating BESS does not amount to supply/generation of electricity for the notified exemptions, so those nil rate/exemption entries are inapplicable. The service is classifiable as support services to electricity transmission and distribution (HSN 998631), liable to GST at 18%, and the operator must register for GST in Tamil Nadu if the BESS is established there.
Battery energy storage systems (BESS) are characterised as storage facilities that convert electrical energy to chemical energy and back, and therefore are not generation, transmission or distribution utilities; accordingly, exemption notifications for generation/transmission/distribution do not apply, whether BESS is standalone or co located. The activity of developing and operating BESS does not amount to supply/generation of electricity for the notified exemptions, so those nil rate/exemption entries are inapplicable. The service is classifiable as support services to electricity transmission and distribution (HSN 998631), liable to GST at 18%, and the operator must register for GST in Tamil Nadu if the BESS is established there.
Note: It is a system-generated summary and is for quick reference only.