Road restoration charges constitute taxable services when requested for commercial pipeline activity, requiring reverse-charge GST from the business r...
Interest on delayed release of requisitioned cash includes statutory pre-assessment interest and restitutionary compensation for unlawful post-assessm...
Incomplete inventory records justify rejecting accounts, while profit estimation requires relevant comparable material and interest falls under other ...
Transfer-pricing comparability requires functional alignment; delayed associated-enterprise receivables need separate LIBOR-based benchmarking, while ...
Extended reassessment limitation in search cases requires asset-linked escaped income, invalidating additions based only on unexplained money or expen...
Enhanced tolerance band under section 43CA applies retrospectively, deleting qualifying deemed-sale additions while disputed stamp valuation requires ...
Penalty under Explanation 7 to section 271(1)(c) was not sustainable on a transfer pricing adjustment where the taxpayer used the prescribed TNMM method, disclosed its filters, comparables and operating-margin computation, and acted in good faith with due diligence. Differences over the profit level indicator and treatment of operating items were debatable interpretational issues, not evidence that the arm's length price had been computed outside the statutory framework. Mere differences of opinion on such issues do not attract penalty. The High Court sustained deletion of the penalty and dismissed the Revenue's appeal for want of a substantial question of law.
Penalty under Explanation 7 to section 271(1)(c) was not sustainable on a transfer pricing adjustment where the taxpayer used the prescribed TNMM method, disclosed its filters, comparables and operating-margin computation, and acted in good faith with due diligence. Differences over the profit level indicator and treatment of operating items were debatable interpretational issues, not evidence that the arm's length price had been computed outside the statutory framework. Mere differences of opinion on such issues do not attract penalty. The High Court sustained deletion of the penalty and dismissed the Revenue's appeal for want of a substantial question of law.
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