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...
Transfer of title of goods stored in Free Trade Warehousing Zone (FTWZ) by the appellant to customers in Domestic Tariff Area (DTA) or multiple transfers within FTWZ is covered under paragraph 8(a) of Schedule III of CGST Act, 2017 as "Supply of warehoused goods to any person before clearance for home consumption". It does not fall under paragraph 8(b) regarding endorsement of documents of title to goods. IGST is applicable on such supplies from FTWZ to DTA customers. No reversal of input tax credit is required under amended Section 17(3) of CGST Act for these supplies, except for supplies from duty-free shops at international airports.
Transfer of title of goods stored in Free Trade Warehousing Zone (FTWZ) by the appellant to customers in Domestic Tariff Area (DTA) or multiple transfers within FTWZ is covered under paragraph 8(a) of Schedule III of CGST Act, 2017 as "Supply of warehoused goods to any person before clearance for home consumption". It does not fall under paragraph 8(b) regarding endorsement of documents of title to goods. IGST is applicable on such supplies from FTWZ to DTA customers. No reversal of input tax credit is required under amended Section 17(3) of CGST Act for these supplies, except for supplies from duty-free shops at international airports.
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