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...
Contingency expenses, exempt-income disallowance, and royalty benchmarking: unsupported adjustments were deleted under consistent accounting and trans...
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Entitlement to claim input tax credit - The AAR concluded that the applicant is not entitled to claim ITC for expenses incurred specifically for the restaurant service availing a 5% GST rate without ITC. For general expenses potentially related to other business activities, ITC claims may be subject to restrictions and reversal as per the relevant GST provisions and rules. Rule 42/43 of the CGST Rules regarding the apportionment and reversal of ITC are applicable to the applicant's case.
Entitlement to claim input tax credit - The AAR concluded that the applicant is not entitled to claim ITC for expenses incurred specifically for the restaurant service availing a 5% GST rate without ITC. For general expenses potentially related to other business activities, ITC claims may be subject to restrictions and reversal as per the relevant GST provisions and rules. Rule 42/43 of the CGST Rules regarding the apportionment and reversal of ITC are applicable to the applicant's case.
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