Transfer pricing requires evidence for AMP transactions, functionally reliable comparables, and appropriate aggregation or Berry Ratio benchmarking me...
Revisionary jurisdiction cannot reopen share capital assessments where adequate inquiry supports a permissible view and no independent error is establ...
Reassessment jurisdiction fails where unverified portal information is aggregated without examining the taxpayer's explanation or relevance of entries...
Statutory sanction for delayed reassessment requires approval from the prescribed authority; approval by an inferior authority invalidates jurisdictio...
Transfer pricing margin adjustments require matching treatment of non-operating income and related costs, with comparability issues reconsidered on ev...
Preliminary-expense amortisation and MAT exempt-income adjustments prevailed, while trademark costs and managerial remuneration require fresh verifica...
Export valuation requires contemporaneous evidence; unrelated invoices cannot prove overvaluation, and dual penalties on firm and partner are impermis...
The Appellate Authority for Advance Ruling (AAAR) rejected the classification under SAC Heading 9986 (support services to oil and gas extraction) and SAC Heading 9983 (other professional, technical, and business services relating to exploration, mining, or drilling of petroleum crude or natural gas) as proposed by the Appellant. Instead, it was held that the services provided under the EPC contract fall under SAC Heading 9954, related to construction services, and are thus taxable at 18%. The reasoning was based on the nature of the contract which encompasses comprehensive activities including surveying, designing, installation, commissioning, and handing over of a functional project, indicating the creation of an immovable property, characteristic of construction services. - Given the classification under SAC Heading 9954, the services are subject to GST at 18%.
The Appellate Authority for Advance Ruling (AAAR) rejected the classification under SAC Heading 9986 (support services to oil and gas extraction) and SAC Heading 9983 (other professional, technical, and business services relating to exploration, mining, or drilling of petroleum crude or natural gas) as proposed by the Appellant. Instead, it was held that the services provided under the EPC contract fall under SAC Heading 9954, related to construction services, and are thus taxable at 18%. The reasoning was based on the nature of the contract which encompasses comprehensive activities including surveying, designing, installation, commissioning, and handing over of a functional project, indicating the creation of an immovable property, characteristic of construction services. - Given the classification under SAC Heading 9954, the services are subject to GST at 18%.
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