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 key aspects covered are the applicable GST rates for services provided by the applicant to Maharashtra Jeevan Pradhikaran (MJP) as part of the Jal Jeevan Mission, based on the time of supply. Services provided before 01.01.2022 are exempt under Entry 3 of Notification 12/2017-Central Tax (Rate), while those after 01.01.2022 are taxable at 18% GST. The authority examined whether MJP qualifies as a 'Government Authority' under the exemption entry and concluded that for services after 01.01.2022, MJP does not meet the criteria due to the omission of 'Government Authority' from the entry. The role of MJP as an agency implementing water supply schemes under constitutional provisions was analyzed, with the authority determining that MJP's actions exceed the scope of an agency. The summary covers the key legal aspects, GST rates, and the rationale behind the rulings based on the relevant notifications and constitutional provisions.
The key aspects covered are the applicable GST rates for services provided by the applicant to Maharashtra Jeevan Pradhikaran (MJP) as part of the Jal Jeevan Mission, based on the time of supply. Services provided before 01.01.2022 are exempt under Entry 3 of Notification 12/2017-Central Tax (Rate), while those after 01.01.2022 are taxable at 18% GST. The authority examined whether MJP qualifies as a 'Government Authority' under the exemption entry and concluded that for services after 01.01.2022, MJP does not meet the criteria due to the omission of 'Government Authority' from the entry. The role of MJP as an agency implementing water supply schemes under constitutional provisions was analyzed, with the authority determining that MJP's actions exceed the scope of an agency. The summary covers the key legal aspects, GST rates, and the rationale behind the rulings based on the relevant notifications and constitutional provisions.
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