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 cooperative society that confined lending and deposit-related activities to its own members was held not liable to service tax under Banking and Other Financial Services. Applying the principle of mutuality, the Tribunal found that services rendered by such a society to its members do not constitute taxable services provided by one person to another. The contrary view treating the society as a commercial concern was unsustainable, and the demand of service tax and related penalties based on member-based services were set aside.
A registered cooperative society that confined lending and deposit-related activities to its own members was held not liable to service tax under Banking and Other Financial Services. Applying the principle of mutuality, the Tribunal found that services rendered by such a society to its members do not constitute taxable services provided by one person to another. The contrary view treating the society as a commercial concern was unsustainable, and the demand of service tax and related penalties based on member-based services were set aside.
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