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 authority cannot admit the application as the questions raised do not fall under the purview of section 97(2) of the CGST/KSGST Act 2017. Section 98 specifies the procedures for processing an advance ruling application, including forwarding a copy to the jurisdictional officer, examining records, and conducting hearings. The authority must reject the application if the questions raised are already pending or decided in any proceedings under the CGST/SGST Act for the applicant. The applicant did not raise any other related or associated questions.
The authority cannot admit the application as the questions raised do not fall under the purview of section 97(2) of the CGST/KSGST Act 2017. Section 98 specifies the procedures for processing an advance ruling application, including forwarding a copy to the jurisdictional officer, examining records, and conducting hearings. The authority must reject the application if the questions raised are already pending or decided in any proceedings under the CGST/SGST Act for the applicant. The applicant did not raise any other related or associated questions.
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