Proper-officer jurisdiction under UPGST penalty provisions upheld; participation on merits prevents bypassing the statutory appellate remedy through w...
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...
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Under TNMM, comparables engaged in trading of medical equipment were retained where product identity was not required and the assessee had not challenged the TPO's search keywords. MDD Medical Systems Pvt. Ltd. and RMD Mediaids Ltd. were not excluded on the basis of alleged support-services activity, research and development, or product dissimilarity because their financials indicated product sales and similar trading functions. QMS Medical Allied Services Pvt. Ltd. was not treated as an extraordinary-event comparable merely because of fresh capital infusion, although the Assessing Officer was directed to verify the margin computation. Hoya Medical India Pvt. Ltd. and Hicks Thermometer (India) Pvt. Ltd. were remitted for verification of RPT compliance, filters, and functional profile, with exclusion or inclusion to follow the verified results.
Under TNMM, comparables engaged in trading of medical equipment were retained where product identity was not required and the assessee had not challenged the TPO's search keywords. MDD Medical Systems Pvt. Ltd. and RMD Mediaids Ltd. were not excluded on the basis of alleged support-services activity, research and development, or product dissimilarity because their financials indicated product sales and similar trading functions. QMS Medical Allied Services Pvt. Ltd. was not treated as an extraordinary-event comparable merely because of fresh capital infusion, although the Assessing Officer was directed to verify the margin computation. Hoya Medical India Pvt. Ltd. and Hicks Thermometer (India) Pvt. Ltd. were remitted for verification of RPT compliance, filters, and functional profile, with exclusion or inclusion to follow the verified results.
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