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 Advance Ruling Authority in Tamil Nadu addressed the liability of an exporter (M/s. DCW Ltd.) under Reverse Charge Mechanism (RCM) to pay GST on export freight on Free on Board (FOB) basis. The exporter was found not liable for GST on RCM basis as they are not involved in arranging export freight. The shipping line accepting goods from the exporter was not required to pay GST on RCM basis as they were not the applicant and not involved in the transaction. The question of GST liability on export freight and whether it constitutes an inter-state supply subject to IGST was deemed irrelevant as it did not pertain to the exporter. The determination of taxable value in the absence of known freight value was not addressed due to the preceding conclusions.
The Advance Ruling Authority in Tamil Nadu addressed the liability of an exporter (M/s. DCW Ltd.) under Reverse Charge Mechanism (RCM) to pay GST on export freight on Free on Board (FOB) basis. The exporter was found not liable for GST on RCM basis as they are not involved in arranging export freight. The shipping line accepting goods from the exporter was not required to pay GST on RCM basis as they were not the applicant and not involved in the transaction. The question of GST liability on export freight and whether it constitutes an inter-state supply subject to IGST was deemed irrelevant as it did not pertain to the exporter. The determination of taxable value in the absence of known freight value was not addressed due to the preceding conclusions.
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