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 explanation to Entry No.234 prescribes treating supplies of Solar Power Generating Systems as subject to a statutory 70:30 apportionment between goods and services, producing a uniform effective tax rate of 8.9% on the gross consideration; this apportionment applies even where supplies arise under contracts described as works contracts. The Court set aside the impugned assessment for April 2018-March 2020 and remanded to the Assessing Authority to recompute tax by applying the 70:30 split and 8.9% effective rate on gross consideration and to verify whether correct tax and interest have been paid. The movable/immovable character of the contracts was left open.
The explanation to Entry No.234 prescribes treating supplies of Solar Power Generating Systems as subject to a statutory 70:30 apportionment between goods and services, producing a uniform effective tax rate of 8.9% on the gross consideration; this apportionment applies even where supplies arise under contracts described as works contracts. The Court set aside the impugned assessment for April 2018-March 2020 and remanded to the Assessing Authority to recompute tax by applying the 70:30 split and 8.9% effective rate on gross consideration and to verify whether correct tax and interest have been paid. The movable/immovable character of the contracts was left open.
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