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 appellant M/s. Gajanand Foods P Ltd's various flour mixes containing spices and ingredients like sugar, semolina, salt, sesame seed, chili powder, garam masala, etc. in addition to flours of dried leguminous vegetables, rice and wheat, were held to be excluded from classification under Chapter Heading 1102 or 1106 of the Customs Tariff Act, 1975 attracting 18% GST. The products cannot be considered as mere flours improved by addition of very small quantities of specified substances. The appeal filed by the appellant against the Advance Ruling passed by the Gujarat Authority for Advance Ruling rejected by the Appellate Authority for Advance Ruling.
The appellant M/s. Gajanand Foods P Ltd's various flour mixes containing spices and ingredients like sugar, semolina, salt, sesame seed, chili powder, garam masala, etc. in addition to flours of dried leguminous vegetables, rice and wheat, were held to be excluded from classification under Chapter Heading 1102 or 1106 of the Customs Tariff Act, 1975 attracting 18% GST. The products cannot be considered as mere flours improved by addition of very small quantities of specified substances. The appeal filed by the appellant against the Advance Ruling passed by the Gujarat Authority for Advance Ruling rejected by the Appellate Authority for Advance Ruling.
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