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...
Rebate received from a bank for payment of excise duty through a corporate card was treated by the AAR as a post-transaction monetary adjustment, not consideration for an identifiable supply of goods or services. Because taxable supply under the GST law requires consideration and a quid pro quo, and the rebate merely reduced the applicant's monetary liability, it fell within a transaction in money and outside the scope of supply. The Authority also noted the arrangement operated as short-term financial accommodation, with the rebate functioning as a discount linked to that facility. The rebate was therefore not liable to GST.
Rebate received from a bank for payment of excise duty through a corporate card was treated by the AAR as a post-transaction monetary adjustment, not consideration for an identifiable supply of goods or services. Because taxable supply under the GST law requires consideration and a quid pro quo, and the rebate merely reduced the applicant's monetary liability, it fell within a transaction in money and outside the scope of supply. The Authority also noted the arrangement operated as short-term financial accommodation, with the rebate functioning as a discount linked to that facility. The rebate was therefore not liable to GST.
Note: It is a system-generated summary and is for quick reference only.