Writ relief against show cause notices is available where jurisdiction is absent and concluded advance rulings cannot be reopened without fresh fraud ...
Section 80P business attribution: ITAT allows deduction on investment interest and ancillary receipts, but excludes staff-loan and other non-eligible ...
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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