Transfer pricing comparables and adjustments: Tribunal revisits loss-maker status, segmental comparability, working capital relief, and risk allocatio...
Business expenditure disallowance failed where commission, related-party salary and promotion payments were supported by records and inquiry was inade...
Advance rulings bind only the applicant and the concerned or jurisdictional tax officer; third parties cannot claim their benefit or challenge them. A recipient contractually required to reimburse applicable GST lacked locus standi to challenge a supplier's advance ruling because the contract did not fix the supply classification or GST rate. "Applicable GST" meant tax determined under law, and the ruling did not alter any contractual tax treatment. As the recipient was neither the applicant nor a concerned authority, it was not an aggrieved person and its writ petition was not maintainable.
Advance rulings bind only the applicant and the concerned or jurisdictional tax officer; third parties cannot claim their benefit or challenge them. A recipient contractually required to reimburse applicable GST lacked locus standi to challenge a supplier's advance ruling because the contract did not fix the supply classification or GST rate. "Applicable GST" meant tax determined under law, and the ruling did not alter any contractual tax treatment. As the recipient was neither the applicant nor a concerned authority, it was not an aggrieved person and its writ petition was not maintainable.
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