Transitioned CENVAT credit may validly satisfy mandatory pre-deposit requirements for legacy service tax appeals through Electronic Credit Ledger debi...
Building-plan sanction charges require statutory authority; unauthorised fees and GST were quashed, while labour cess must follow prescribed collectio...
Pure-agent exclusion fails where hotel booking facilitators receive third-party services themselves, making entire customer consideration taxable as r...
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...
A second final assessment order for the same assessment year was held impermissible because a final order had already been passed pursuant to DRP directions; the later order was quashed as a duplicate assessment. Transfer pricing issues on intra-group services and royalty benchmarking were not finally decided and were remitted to the TPO for fresh adjudication and computation in line with earlier-year directions. Support service expenditure was held allowable on consistency with prior years, and the disallowance was deleted. Amortization of telecom licence fee and the related interest claim were sent back for consequential action in accordance with law. Deduction under section 80G for CSR expenditure, refund of excess dividend distribution tax at treaty rate, and road tax and VAT on leased assets were all allowed.
A second final assessment order for the same assessment year was held impermissible because a final order had already been passed pursuant to DRP directions; the later order was quashed as a duplicate assessment. Transfer pricing issues on intra-group services and royalty benchmarking were not finally decided and were remitted to the TPO for fresh adjudication and computation in line with earlier-year directions. Support service expenditure was held allowable on consistency with prior years, and the disallowance was deleted. Amortization of telecom licence fee and the related interest claim were sent back for consequential action in accordance with law. Deduction under section 80G for CSR expenditure, refund of excess dividend distribution tax at treaty rate, and road tax and VAT on leased assets were all allowed.
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