Reopening of assessment cannot rest solely on an audit party's opinion; reassessment under Section 147/148 is impermissible and power of revision shou...
Tested party selection: functional analysis identified the least complex unit as the appropriate tested party, altering the transfer pricing adjustmen...
Event management activity involving planning and organising weddings, exhibitions and similar events was treated as taxable Event Management Service. For valuation, only the commission retained by the appellant could form part of the assessable value; amounts collected merely for payment to third-party vendors were excluded, so the demand on gross receipts failed. Loose papers, uncertified computer printouts and uncorroborated statements were held insufficient to prove clandestine transactions, and the burden remained on the Revenue. The extended period of limitation was wrongly invoked for want of proof of suppression or intent to evade, and the proceedings, including penalties, were set aside as time-barred.
Event management activity involving planning and organising weddings, exhibitions and similar events was treated as taxable Event Management Service. For valuation, only the commission retained by the appellant could form part of the assessable value; amounts collected merely for payment to third-party vendors were excluded, so the demand on gross receipts failed. Loose papers, uncertified computer printouts and uncorroborated statements were held insufficient to prove clandestine transactions, and the burden remained on the Revenue. The extended period of limitation was wrongly invoked for want of proof of suppression or intent to evade, and the proceedings, including penalties, were set aside as time-barred.
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