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 ruling addressed the eligibility of Input Tax Credit (ITC) for cars used for demonstration purposes. It was held that demo cars can be eligible for ITC if certain conditions are met, particularly if they are intended for further supply after the demo period. The use of cars for demos does not disqualify them from ITC if they are later used for making supplies. The applicant can claim ITC on demo cars if they are subsequently used for supply. However, this entitlement is subject to conditions, such as not claiming depreciation on the tax component of demo cars' cost and ensuring they are used for further supply. The ruling was made by the Advance Ruling Authority (AAR).
The ruling addressed the eligibility of Input Tax Credit (ITC) for cars used for demonstration purposes. It was held that demo cars can be eligible for ITC if certain conditions are met, particularly if they are intended for further supply after the demo period. The use of cars for demos does not disqualify them from ITC if they are later used for making supplies. The applicant can claim ITC on demo cars if they are subsequently used for supply. However, this entitlement is subject to conditions, such as not claiming depreciation on the tax component of demo cars' cost and ensuring they are used for further supply. The ruling was made by the Advance Ruling Authority (AAR).
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