Permanent-establishment reassessment cannot revisit scrutinised disclosures; extended reopening fails without undisclosed material facts and within st...
Modified returns after business reorganisation must be assessed within pending proceedings, barring parallel scrutiny and consequential transfer prici...
Turnover mismatches under percentage-completion accounting cannot alone establish suppressed income where customer advances remain recorded as liabili...
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The statutory bar on admission of an advance-ruling application applies where the same question concerning the applicant is already pending or has been decided in proceedings. A transporter's supply-characterisation question-whether making vehicles available to another goods transport agency is exempt or taxable-formed the basis of a pending input-tax-credit reversal proceeding and had been decided for an earlier tax period. Both grounds precluded examination of classification, exemption, or taxability on the merits, and the application was rejected as not maintainable.
The statutory bar on admission of an advance-ruling application applies where the same question concerning the applicant is already pending or has been decided in proceedings. A transporter's supply-characterisation question-whether making vehicles available to another goods transport agency is exempt or taxable-formed the basis of a pending input-tax-credit reversal proceeding and had been decided for an earlier tax period. Both grounds precluded examination of classification, exemption, or taxability on the merits, and the application was rejected as not maintainable.
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