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...
Rate of tax applicable on services provided by the applicant to Maharashtra Jeevan Pradhikaran (MJP) as part of the Jal Jeevan Mission, a Government of India mission. The services are classified as "Technical Consultancy for Project Development and Management support services" under SAC code 998399, attracting 18% GST (9% CGST & 9% SGST), unless exempted. For services provided before 01.01.2022, the exemption under Entry No. 3 of Notification No. 12/2017-Central Tax (Rate) is applicable. However, for services provided on or after 01.01.2022, the exemption is not available due to the omission of "Government Authorities" from the notification entry. The applicant's argument that services are provided to Central and State Governments, thus eligible for exemption, is rejected as speculative. The issue of whether MJP's appointment amounts to delegation of sovereign functions under the Constitution is deemed outside the purview of Section 97(2) of the GST Act.
Rate of tax applicable on services provided by the applicant to Maharashtra Jeevan Pradhikaran (MJP) as part of the Jal Jeevan Mission, a Government of India mission. The services are classified as "Technical Consultancy for Project Development and Management support services" under SAC code 998399, attracting 18% GST (9% CGST & 9% SGST), unless exempted. For services provided before 01.01.2022, the exemption under Entry No. 3 of Notification No. 12/2017-Central Tax (Rate) is applicable. However, for services provided on or after 01.01.2022, the exemption is not available due to the omission of "Government Authorities" from the notification entry. The applicant's argument that services are provided to Central and State Governments, thus eligible for exemption, is rejected as speculative. The issue of whether MJP's appointment amounts to delegation of sovereign functions under the Constitution is deemed outside the purview of Section 97(2) of the GST Act.
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