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...
Entry No. 59 of Notification No. 01/2017 Central Tax (Rate) dated 28.06.2017, as amended by Notification 06/2022-Central Tax (Rate) dated 13.07.2022, mentions 'Meal and powder of the dried leguminous vegetables' but the applicant's product 'pushti' is a powdered mixture of cereals, pulses, and sugar, hence not covered under this entry. Entry No. 78 of Notification No. 02/2027 Central Tax (Rates) dated 28.06.2017, as amended by Notification No. 07/2022 Central Tax (Rate) dated 13.07.2022, mentions 'Flour of the dried leguminous vegetables' but the applicant's product 'pushti' is a powdered mixture of cereals, pulses, and sugar, hence not covered under this entry. Exemption under S.N.66 clause (b) (ii) of Notification No. 12/2017-Central Tax (Rate) dated 28.06.2017 and Circular No. 149/05/2021-GST dated 17.06.2021 is not applicable as the applicant is supplying goods and not services. Clarification No. KSA/GST.CR-05/2019-20 dated 23.06.2021 issued by Karnataka is also not applicable.
Entry No. 59 of Notification No. 01/2017 Central Tax (Rate) dated 28.06.2017, as amended by Notification 06/2022-Central Tax (Rate) dated 13.07.2022, mentions 'Meal and powder of the dried leguminous vegetables' but the applicant's product 'pushti' is a powdered mixture of cereals, pulses, and sugar, hence not covered under this entry. Entry No. 78 of Notification No. 02/2027 Central Tax (Rates) dated 28.06.2017, as amended by Notification No. 07/2022 Central Tax (Rate) dated 13.07.2022, mentions 'Flour of the dried leguminous vegetables' but the applicant's product 'pushti' is a powdered mixture of cereals, pulses, and sugar, hence not covered under this entry. Exemption under S.N.66 clause (b) (ii) of Notification No. 12/2017-Central Tax (Rate) dated 28.06.2017 and Circular No. 149/05/2021-GST dated 17.06.2021 is not applicable as the applicant is supplying goods and not services. Clarification No. KSA/GST.CR-05/2019-20 dated 23.06.2021 issued by Karnataka is also not applicable.
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