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 involves a query regarding the classification of goods and services for GST purposes. The applicant sought clarification on the consideration charged for supplying aggregates and recovering royalty charges. The ruling determined that the applicant's tax collection on royalty charges and goods supplied separately in invoices indicated distinct transactions. Royalty charges were classified under SAC 997337, attracting 9% CGST and 9% SGST, while aggregates fell under HSN code 251710, subject to CGST @2.5% and SGST @2.5%. The ruling emphasized the separate nature of the transactions, not constituting mixed or composite supply.
The case involves a query regarding the classification of goods and services for GST purposes. The applicant sought clarification on the consideration charged for supplying aggregates and recovering royalty charges. The ruling determined that the applicant's tax collection on royalty charges and goods supplied separately in invoices indicated distinct transactions. Royalty charges were classified under SAC 997337, attracting 9% CGST and 9% SGST, while aggregates fell under HSN code 251710, subject to CGST @2.5% and SGST @2.5%. The ruling emphasized the separate nature of the transactions, not constituting mixed or composite supply.
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