Pre-amendment reassessment limitation bars late notices under the preserved regime, invalidating consequential reassessment for affected earlier asses...
Cash-sales explanations for bank deposits require documentary reconciliation; reassessment notice survived where effective response time was available...
Functional comparability in transfer pricing prevents ad hoc arm's length adjustments where functions, assets, risks and reliable comparables are unes...
Levy of GST - distinct persons - supply of goods or supply of services - The transfer of right to do integration testing, installation and marketing software from the applicant to Karnataka Cost centre is leviable to GST as such transaction is being executed between two distinct persons i.e., two cost centers of the same entity. Further as such supply is found to be involving only transfer of the said right, it is concluded that the supply is of services and not of goods. - AAR
Levy of GST - distinct persons - supply of goods or supply of services - The transfer of right to do integration testing, installation and marketing software from the applicant to Karnataka Cost centre is leviable to GST as such transaction is being executed between two distinct persons i.e., two cost centers of the same entity. Further as such supply is found to be involving only transfer of the said right, it is concluded that the supply is of services and not of goods. - AAR
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