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 (ARA) addressed the interpretation of the expression "parts of goods of headings 8901, 8902, 8904, 8905, 8906, 8907" in specific notifications. The key issue was whether the goods/spares used were parts of warships/submarines. The ARA held that essential components like engines, gearbox, propeller, etc., are integral parts of a ship/vessel based on definitions of "part." Goods qualifying as parts of specific headings attract GST under the relevant notification. Items listed in Annexure 2A were deemed essential parts of a warship/submarine and subject to specific GST rates, while others in different annexures were not covered under the said notification.
The Advance Ruling Authority (ARA) addressed the interpretation of the expression "parts of goods of headings 8901, 8902, 8904, 8905, 8906, 8907" in specific notifications. The key issue was whether the goods/spares used were parts of warships/submarines. The ARA held that essential components like engines, gearbox, propeller, etc., are integral parts of a ship/vessel based on definitions of "part." Goods qualifying as parts of specific headings attract GST under the relevant notification. Items listed in Annexure 2A were deemed essential parts of a warship/submarine and subject to specific GST rates, while others in different annexures were not covered under the said notification.
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