Transfer pricing comparability requires functional alignment and permits working capital adjustment, while APA margins cannot govern non-covered years...
Treaty benefit, goodwill depreciation and hedging costs: export commission disallowed, while key business deductions and depreciation claims succeeded...
Undisclosed foreign asset classification requires an unexplained source; unrebutted affidavits and corroborative evidence defeated the Black Money Act...
An advance ruling application was held non-admissible because it sought to regularise a completed transaction: the prescribed fee had already been paid before the ruling request, so the matter lay outside the advance ruling mechanism. On taxability, the permission granted for conversion of wetland to dry land was treated as a specific regulatory service conferring a direct private benefit, making the statutory fee consideration for supply of service. The activity was held outside the functions entrusted to Panchayats under Article 243G and the Eleventh Schedule, so the claimed exemption failed. Accordingly, GST was held payable under reverse charge on the fee.
An advance ruling application was held non-admissible because it sought to regularise a completed transaction: the prescribed fee had already been paid before the ruling request, so the matter lay outside the advance ruling mechanism. On taxability, the permission granted for conversion of wetland to dry land was treated as a specific regulatory service conferring a direct private benefit, making the statutory fee consideration for supply of service. The activity was held outside the functions entrusted to Panchayats under Article 243G and the Eleventh Schedule, so the claimed exemption failed. Accordingly, GST was held payable under reverse charge on the fee.
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