Pre-amendment reassessment limitation bars late notices under the preserved regime, invalidating consequential reassessment for affected earlier asses...
Cash-sales explanations for bank deposits require documentary reconciliation; reassessment notice survived where effective response time was available...
Functional comparability in transfer pricing prevents ad hoc arm's length adjustments where functions, assets, risks and reliable comparables are unes...
Contingency expenses, exempt-income disallowance, and royalty benchmarking: unsupported adjustments were deleted under consistent accounting and trans...
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The AAAR determined that the appeal was not maintainable as the AAR had failed to address three questions in its original ruling. Since the questions regarding GST on developed plot sales, development services to landowners, transfer of development rights, valuation of services, and timing of tax payments were interlinked, the AAAR could not effectively decide on the partial ruling. Despite Section 101 of CGST Act, 2017 lacking explicit remand provisions, the AAAR set aside the lower authority's order and remanded the matter to the AAR for fresh consideration to ensure complete adjudication of all interrelated questions.
The AAAR determined that the appeal was not maintainable as the AAR had failed to address three questions in its original ruling. Since the questions regarding GST on developed plot sales, development services to landowners, transfer of development rights, valuation of services, and timing of tax payments were interlinked, the AAAR could not effectively decide on the partial ruling. Despite Section 101 of CGST Act, 2017 lacking explicit remand provisions, the AAAR set aside the lower authority's order and remanded the matter to the AAR for fresh consideration to ensure complete adjudication of all interrelated questions.
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