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 joint development agreement does not, by itself, create a taxable works contract for the landowner's share: VAT can arise only from the developer's construction obligations once agreements with flat purchasers are executed for monetary consideration. An exchange of an undivided share in land for a corresponding built-up share is barter, not sale, because no price moves from the landowner to the developer. Entry 54 of List II permits tax only on the goods element in a works contract, so levy on land or immovable property is outside legislative competence. A circular cannot supply a missing statutory machinery for valuation, and the composition scheme cannot enlarge taxability to non-taxable land value.
A joint development agreement does not, by itself, create a taxable works contract for the landowner's share: VAT can arise only from the developer's construction obligations once agreements with flat purchasers are executed for monetary consideration. An exchange of an undivided share in land for a corresponding built-up share is barter, not sale, because no price moves from the landowner to the developer. Entry 54 of List II permits tax only on the goods element in a works contract, so levy on land or immovable property is outside legislative competence. A circular cannot supply a missing statutory machinery for valuation, and the composition scheme cannot enlarge taxability to non-taxable land value.
Note: It is a system-generated summary and is for quick reference only.
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