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...
A registered recipient may seek an advance ruling where the transaction affects its tax position, because the term "applicant" is broad enough to cover such a request; the locus objection was therefore rejected and the ruling was examined on merits. On classification, crushing, screening and sizing of limestone/dolomite did not amount to manufacture because the processes did not produce a new product with a distinct name, character and use; the mineral identity and commercial understanding remained unchanged, with only physical dimensions altered. The contractor's assumption of operational risk was irrelevant. The activity was treated as treatment or processing of another person's goods and therefore a supply of service in the nature of job work.
A registered recipient may seek an advance ruling where the transaction affects its tax position, because the term "applicant" is broad enough to cover such a request; the locus objection was therefore rejected and the ruling was examined on merits. On classification, crushing, screening and sizing of limestone/dolomite did not amount to manufacture because the processes did not produce a new product with a distinct name, character and use; the mineral identity and commercial understanding remained unchanged, with only physical dimensions altered. The contractor's assumption of operational risk was irrelevant. The activity was treated as treatment or processing of another person's goods and therefore a supply of service in the nature of job work.
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