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 applicant purchases vouchers by paying consideration to the issuer and sells them to clients for consideration. The vouchers have value and ownership transferrable from issuer to applicant and then to ultimate beneficiary. No service element exists between issuer and applicant or applicant and purchaser. Vouchers qualify as movable property and goods. Actionable claims other than lottery, betting, and gambling are neither goods nor services supply under GST. The applicant is involved in trading vouchers for consideration in business, selling at profit. This transaction amounts to supply of goods u/s 7(1)(a) of CGST Act 2017, involving title transfer covered under "goods" as per Schedule II. The vouchers are taxable as per residual entry no. 453 of Third Schedule of N/N. 01/2017-Central Tax (Rate) at 9% CGST and 9% UPGST rate.
The applicant purchases vouchers by paying consideration to the issuer and sells them to clients for consideration. The vouchers have value and ownership transferrable from issuer to applicant and then to ultimate beneficiary. No service element exists between issuer and applicant or applicant and purchaser. Vouchers qualify as movable property and goods. Actionable claims other than lottery, betting, and gambling are neither goods nor services supply under GST. The applicant is involved in trading vouchers for consideration in business, selling at profit. This transaction amounts to supply of goods u/s 7(1)(a) of CGST Act 2017, involving title transfer covered under "goods" as per Schedule II. The vouchers are taxable as per residual entry no. 453 of Third Schedule of N/N. 01/2017-Central Tax (Rate) at 9% CGST and 9% UPGST rate.
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