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...
AAR ruled that businesses can utilize Rule 32(5) valuation (margin scheme) for second-hand goods while maintaining regular valuation for existing operations. Taxpayers may selectively apply this scheme to purchases from unregistered dealers while using standard GST procedures for registered dealer purchases. Under the margin scheme, the taxable value is the difference between selling price and purchase price, excluding repair/improvement costs. When using this scheme, input tax credit cannot be claimed on either purchase price or repair costs. Purchases of second-hand goods from unregistered dealers are exempt from reverse charge mechanism for intra-state supplies under Notification No. 10/2017-CT(R).
AAR ruled that businesses can utilize Rule 32(5) valuation (margin scheme) for second-hand goods while maintaining regular valuation for existing operations. Taxpayers may selectively apply this scheme to purchases from unregistered dealers while using standard GST procedures for registered dealer purchases. Under the margin scheme, the taxable value is the difference between selling price and purchase price, excluding repair/improvement costs. When using this scheme, input tax credit cannot be claimed on either purchase price or repair costs. Purchases of second-hand goods from unregistered dealers are exempt from reverse charge mechanism for intra-state supplies under Notification No. 10/2017-CT(R).
Note: It is a system-generated summary and is for quick reference only.
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