Transfer pricing comparability requires functional alignment, reliable financial data, and careful review of working capital and receivables adjustmen...
Transfer pricing rules require benchmarking corporate guarantees and associated-enterprise advances, while invalid domestic-transaction adjustments ca...
The application for advance ruling is liable for rejection under the first proviso to Section 98(2) of the CGST/TNGST Acts, 2017, as proceedings on the same issue were already initiated and pending against the applicant. The initiation of investigation through summons, recording of statements, furnishing of details by the applicant, and issuance of an Incident Report by DGGI, all preceded the filing of the advance ruling application. Pronouncing a ruling on an issue under investigation may vitiate the adjudication proceedings involving the show cause notice. The scope of 'proceedings' under the CGST Act encompasses investigations initiated against the applicant, involving the same issue raised in the advance ruling query.
The application for advance ruling is liable for rejection under the first proviso to Section 98(2) of the CGST/TNGST Acts, 2017, as proceedings on the same issue were already initiated and pending against the applicant. The initiation of investigation through summons, recording of statements, furnishing of details by the applicant, and issuance of an Incident Report by DGGI, all preceded the filing of the advance ruling application. Pronouncing a ruling on an issue under investigation may vitiate the adjudication proceedings involving the show cause notice. The scope of 'proceedings' under the CGST Act encompasses investigations initiated against the applicant, involving the same issue raised in the advance ruling query.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4803
Join Channel
TaxTMI 
