Transfer pricing comparability requires functional alignment and permits working capital adjustment, while APA margins cannot govern non-covered years...
Treaty benefit, goodwill depreciation and hedging costs: export commission disallowed, while key business deductions and depreciation claims succeeded...
Undisclosed foreign asset classification requires an unexplained source; unrebutted affidavits and corroborative evidence defeated the Black Money Act...
Proceedings under the CGST Act, 2017 encompass not just judicial proceedings but also assessment, audit, detention/seizure/release of goods and conveyances, even if they do not culminate in a show cause notice. Investigation or inquiry initiated to safeguard government revenue qualifies as proceedings. The applicant's contention that inquiry/investigation does not constitute proceedings is misconceived. Since investigation by DGGI predated the applicant's advance ruling application on the same issue, the application is liable for rejection under the first proviso to Section 98(2) of the CGST/TNGST Acts, 2017. Consequently, the advance ruling application is rejected.
Proceedings under the CGST Act, 2017 encompass not just judicial proceedings but also assessment, audit, detention/seizure/release of goods and conveyances, even if they do not culminate in a show cause notice. Investigation or inquiry initiated to safeguard government revenue qualifies as proceedings. The applicant's contention that inquiry/investigation does not constitute proceedings is misconceived. Since investigation by DGGI predated the applicant's advance ruling application on the same issue, the application is liable for rejection under the first proviso to Section 98(2) of the CGST/TNGST Acts, 2017. Consequently, the advance ruling application is rejected.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4805
Join Channel
TaxTMI 
