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...
The ruling determines that bundled sale of printing inks and various consumables is not a composite supply because the bundle is not 'naturally bundled' nor does any single good qualify as the 'principal supply'; instead the package is a mixed supply and taxable accordingly. The supply is a continuous supply with periodic invoicing; time of supply is the earlier of invoice date or payment under Section 12(2). Transaction value is the per-click/per-impression amount stated in the invoice and governs valuation under Section 15.
The ruling determines that bundled sale of printing inks and various consumables is not a composite supply because the bundle is not 'naturally bundled' nor does any single good qualify as the 'principal supply'; instead the package is a mixed supply and taxable accordingly. The supply is a continuous supply with periodic invoicing; time of supply is the earlier of invoice date or payment under Section 12(2). Transaction value is the per-click/per-impression amount stated in the invoice and governs valuation under Section 15.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4796
Join Channel
TaxTMI 
