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 case concerns the liability of an exporter to pay GST on export freight as CGST & SGST or IGST. The ruling states that post the sunset clause on ocean/air freight, such activities became taxable under GST from 1.10.2022. The tax liability depends on the 'place of supply,' which, in this case, is 'outside India,' making it an inter-state supply subject to IGST. If the service provider, the shipping line, has an office in Thoothukudi, Tamilnadu, the liability shifts to CGST/SGST for intra-state supply. The exporter is not liable for GST as it receives the service as input for its CIF basis exports. The ruling does not address the liability of the shipping line for GST.
The case concerns the liability of an exporter to pay GST on export freight as CGST & SGST or IGST. The ruling states that post the sunset clause on ocean/air freight, such activities became taxable under GST from 1.10.2022. The tax liability depends on the 'place of supply,' which, in this case, is 'outside India,' making it an inter-state supply subject to IGST. If the service provider, the shipping line, has an office in Thoothukudi, Tamilnadu, the liability shifts to CGST/SGST for intra-state supply. The exporter is not liable for GST as it receives the service as input for its CIF basis exports. The ruling does not address the liability of the shipping line for GST.
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