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...
Prospective sugar export prohibition required registered letters of credit; private contracts and export quotas created no enforceable continuation ri...
Retroactive interim-moratorium exclusion permits protective asset disclosure and preservation measures against personal guarantors pending arbitration...
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The High Court held that respondent No. 3 cannot avoid deciding the petitioners' application dated 20 December 2023 seeking an advance ruling on the taxability of sale of land and buildings, based on the subsequent issuance of a pre-show cause notice dated 22 October 2024 by respondent No. 2 u/s 73(5) read with Rule 142(1-A) of the State Goods and Services Tax Act. The Court directed respondent No. 3 to dispose of the petitioners' application within three months, considering the provisions of Section 98(6) requiring the authority to pronounce the advance ruling within 90 days of receiving the application. The Court observed that if the advance ruling authority rules in favor of the petitioners, such ruling will bind not only respondent No. 2 but also the petitioners, as per Section 103(1). However, the Court cautioned against prematurely rushing to the Court, bypassing alternate remedies, before the authorities have an opportunity to examine the cause and make a decision.
The High Court held that respondent No. 3 cannot avoid deciding the petitioners' application dated 20 December 2023 seeking an advance ruling on the taxability of sale of land and buildings, based on the subsequent issuance of a pre-show cause notice dated 22 October 2024 by respondent No. 2 u/s 73(5) read with Rule 142(1-A) of the State Goods and Services Tax Act. The Court directed respondent No. 3 to dispose of the petitioners' application within three months, considering the provisions of Section 98(6) requiring the authority to pronounce the advance ruling within 90 days of receiving the application. The Court observed that if the advance ruling authority rules in favor of the petitioners, such ruling will bind not only respondent No. 2 but also the petitioners, as per Section 103(1). However, the Court cautioned against prematurely rushing to the Court, bypassing alternate remedies, before the authorities have an opportunity to examine the cause and make a decision.
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