Transfer pricing comparability requires functional alignment and permits working capital adjustment, while APA margins cannot govern non-covered years...
Treaty benefit, goodwill depreciation and hedging costs: export commission disallowed, while key business deductions and depreciation claims succeeded...
Undisclosed foreign asset classification requires an unexplained source; unrebutted affidavits and corroborative evidence defeated the Black Money Act...
The AAAR dismissed the appellant's appeal, upholding the original ruling. The Authority determined it lacked jurisdiction to decide on taxability under Finance Act, 1994 (service tax), as the appellant sought ruling on pre-GST TDR transactions. The AAAR also declined to consider new grounds introduced in appeal that weren't raised before the original authority, citing precedent from Commissioner of Cust & C Ex, Goa vs Dempo Engineering Works Ltd. The ruling confirmed that transfer of development rights constitutes receipt of consideration by the developer, and GST liability arises at the time of transfer of possession or rights in the constructed property, not when development rights are received. The appeal was dismissed accordingly.
The AAAR dismissed the appellant's appeal, upholding the original ruling. The Authority determined it lacked jurisdiction to decide on taxability under Finance Act, 1994 (service tax), as the appellant sought ruling on pre-GST TDR transactions. The AAAR also declined to consider new grounds introduced in appeal that weren't raised before the original authority, citing precedent from Commissioner of Cust & C Ex, Goa vs Dempo Engineering Works Ltd. The ruling confirmed that transfer of development rights constitutes receipt of consideration by the developer, and GST liability arises at the time of transfer of possession or rights in the constructed property, not when development rights are received. The appeal was dismissed accordingly.
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