Third-party loose sheets require reliable nexus before supporting unexplained expenditure additions; presumptions do not establish payer identity or o...
TNMM comparability using audited accounts and working-capital adjustments can eliminate unwarranted transfer-pricing additions where verified margins ...
Gross-profit additions on disputed purchases require reasoned appellate determination; disclosed claims alone do not support inaccurate-particulars pe...
Limitation after transfer-pricing remand: fresh TPO reference did not extend the assessment deadline, rendering the consequential assessment time-barr...
Interim judicial restraint on tax deduction prevents default, while supporting reasonable cause and penalty deletion for foreign-leg LFC reimbursement...
Palmolein classification defeated the crude-oil concession; material misdeclaration sustained recovery and confiscation, while separate false-document...
AAR ruled that reimbursement of electricity charges collected on actual basis from sub-lessees is not subject to GST. The applicant, acting as a pure agent under Rule 33(a), merely recovers the exact electricity costs charged by electricity boards/DISCOMs from sub-lessees. Evidence showed the applicant's invoices matched the original electricity bills, demonstrating a pass-through arrangement. Following recent GST clarifications, property owners and managers collecting actual electricity costs are deemed pure agents for this supply. The reimbursement amount is excluded from the value of supply, and consequently, no GST liability arises on such electricity charge recoveries.
AAR ruled that reimbursement of electricity charges collected on actual basis from sub-lessees is not subject to GST. The applicant, acting as a pure agent under Rule 33(a), merely recovers the exact electricity costs charged by electricity boards/DISCOMs from sub-lessees. Evidence showed the applicant's invoices matched the original electricity bills, demonstrating a pass-through arrangement. Following recent GST clarifications, property owners and managers collecting actual electricity costs are deemed pure agents for this supply. The reimbursement amount is excluded from the value of supply, and consequently, no GST liability arises on such electricity charge recoveries.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4891 
