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...
Painting and end-to-end execution services for residential, commercial and industrial premises were held not to constitute management, maintenance or repair service. The Tribunal noted that the services, on the admitted facts, were more appropriately covered by construction-related activity and that in the appellant's own case for a prior period the original authority had already treated the work as works contract service. The demand raised under management, maintenance or repair service was therefore unsustainable, and the activity was held to be correctly classifiable under works contract service. The impugned order was set aside and consequential relief followed in accordance with law.
Painting and end-to-end execution services for residential, commercial and industrial premises were held not to constitute management, maintenance or repair service. The Tribunal noted that the services, on the admitted facts, were more appropriately covered by construction-related activity and that in the appellant's own case for a prior period the original authority had already treated the work as works contract service. The demand raised under management, maintenance or repair service was therefore unsustainable, and the activity was held to be correctly classifiable under works contract service. The impugned order was set aside and consequential relief followed in accordance with law.
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