Pre-existing operational debt disputes require genuine evidence, while undirected running-account payments may be appropriated on a first-in-first-out...
Agency in CNG distribution makes outlet operators commission agents, rendering taxable Business Auxiliary Service rather than purchasing goods for res...
Composite inpatient healthcare supply may retain exemption despite MRP medicine billing, while separate taxable sale characterisation remains disputed...
Working-capital adjustment determines whether software-services transfer-pricing margins fall within the statutory tolerance range, eliminating any ad...
Permanent establishment deductions upheld for expatriate salaries, direct costs and trading losses, while head-office costs require fresh classificati...
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Advance-ruling jurisdiction is confined to supplies being undertaken or proposed and cannot validate a tax position already adopted for completed transactions. Where pre-GST contractual work had ended, arbitral-award amounts were received, and the taxpayer filed GSTR-3B treating them as non-taxable compensation, the application sought confirmation after the event rather than advance certainty. Questions on whether individual award components constitute consideration require examination of contracts, arbitral materials, accounts, returns and evidence by the proper officer through scrutiny or adjudication. Admission by the original authority does not prevent the appellate authority from examining maintainability. The advance ruling was set aside, without any opinion on taxability of the award amounts.
Advance-ruling jurisdiction is confined to supplies being undertaken or proposed and cannot validate a tax position already adopted for completed transactions. Where pre-GST contractual work had ended, arbitral-award amounts were received, and the taxpayer filed GSTR-3B treating them as non-taxable compensation, the application sought confirmation after the event rather than advance certainty. Questions on whether individual award components constitute consideration require examination of contracts, arbitral materials, accounts, returns and evidence by the proper officer through scrutiny or adjudication. Admission by the original authority does not prevent the appellate authority from examining maintainability. The advance ruling was set aside, without any opinion on taxability of the award amounts.
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