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 addressed two key issues: 1) Whether a supplier, who is the owner of a vehicle, can charge GST on rental/hiring services under the Forward Charge Mechanism even if the service is exempted. The ruling stated that this question is not maintainable as the applicant did not undertake or propose to undertake any supply of renting/hiring vehicles. 2) Whether a Goods Transport Agency can claim Input Tax Credit based on supplier invoices. The ruling clarified that the Agency, paying GST under the Forward Charge Mechanism, can claim ITC under Section 16 of the GST Act 2017, provided conditions are met.
The Advance Ruling Authority addressed two key issues: 1) Whether a supplier, who is the owner of a vehicle, can charge GST on rental/hiring services under the Forward Charge Mechanism even if the service is exempted. The ruling stated that this question is not maintainable as the applicant did not undertake or propose to undertake any supply of renting/hiring vehicles. 2) Whether a Goods Transport Agency can claim Input Tax Credit based on supplier invoices. The ruling clarified that the Agency, paying GST under the Forward Charge Mechanism, can claim ITC under Section 16 of the GST Act 2017, provided conditions are met.
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