Online bond platforms may offer overseas-regulated products and tax-specific bonds subject to disclosures, compliance safeguards and revised complianc...
Corporate guarantee valuation permits actual ascertainable commission while barring retroactive application and extended-period penalties for bona fid...
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...
Royalty on export sales required fresh examination because the Tribunal found that the source of income must be distinguished from the source of receipt, but the Assessing Officer had not fully verified where the export contracts were concluded or whether the royalty was taxed in another jurisdiction; the issue was remanded without final merits adjudication. Management support services were held not to be fee for technical services under the India-Singapore DTAA because that agreement operated independently from the royalty/licensing arrangement, and the assessee succeeded on that issue for all years. On reimbursement of expenses, the DRP lacked power under section 144C(8) to direct further enquiry and fresh determination by the Assessing Officer, so those directions were invalid and the related addition for AY 2022-23 was deleted.
Royalty on export sales required fresh examination because the Tribunal found that the source of income must be distinguished from the source of receipt, but the Assessing Officer had not fully verified where the export contracts were concluded or whether the royalty was taxed in another jurisdiction; the issue was remanded without final merits adjudication. Management support services were held not to be fee for technical services under the India-Singapore DTAA because that agreement operated independently from the royalty/licensing arrangement, and the assessee succeeded on that issue for all years. On reimbursement of expenses, the DRP lacked power under section 144C(8) to direct further enquiry and fresh determination by the Assessing Officer, so those directions were invalid and the related addition for AY 2022-23 was deleted.
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