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...
E-rickshaw supplies in CKD/SKD form qualify for GST treatment as the finished electrically operated vehicle only when all components needed to assemble a complete vehicle are supplied together as one identifiable kit or package, and the consignment contents and contemporaneous commercial records consistently match that description. The AAAR rejected the motor-plus-three-components test because it does not arise from Rule 2(a), the tariff, or the rate notification, and held that individual parts cannot be classified as the finished vehicle merely because some are essential components. It also noted that customs interpretative fiction under Rule 2(a) has a limited scope and cannot be extended beyond customs classification.
E-rickshaw supplies in CKD/SKD form qualify for GST treatment as the finished electrically operated vehicle only when all components needed to assemble a complete vehicle are supplied together as one identifiable kit or package, and the consignment contents and contemporaneous commercial records consistently match that description. The AAAR rejected the motor-plus-three-components test because it does not arise from Rule 2(a), the tariff, or the rate notification, and held that individual parts cannot be classified as the finished vehicle merely because some are essential components. It also noted that customs interpretative fiction under Rule 2(a) has a limited scope and cannot be extended beyond customs classification.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4796
Join Channel
TaxTMI 
