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...
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.
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