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...
Section 22(1) and the definition of "location of supplier of services" frame the registration rule: a supplier must register in the State from which taxable supplies are made, being the place of business or fixed establishment for which registration is obtained. On the facts the applicant has no office or fixed establishment in Rajasthan; its location of supplier is Uttar Pradesh, so it is not obliged to register in Rajasthan merely because the construction site (place of supply) is located there. Concerning inward supplies the Authority could not conclusively determine taxability for want of invoices; as a principle, movement of goods across States attracts IGST, whereas supplies and delivery wholly within the State attract CGST and SGST.
Section 22(1) and the definition of "location of supplier of services" frame the registration rule: a supplier must register in the State from which taxable supplies are made, being the place of business or fixed establishment for which registration is obtained. On the facts the applicant has no office or fixed establishment in Rajasthan; its location of supplier is Uttar Pradesh, so it is not obliged to register in Rajasthan merely because the construction site (place of supply) is located there. Concerning inward supplies the Authority could not conclusively determine taxability for want of invoices; as a principle, movement of goods across States attracts IGST, whereas supplies and delivery wholly within the State attract CGST and SGST.
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