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...
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The AAR determined that the inclusion of a free scraping tool with Apsara Oil Pastels constitutes a "mixed supply" under section 2(74) of the CGST Act, 2017, rather than a composite supply. The authority rejected the applicant's contention that the scraping tool was merely an accessory, finding that the two products were not integral to each other's function. Since the products were supplied together for a single price, section 8(b) of the CGST Act applies, requiring taxation at the higher applicable rate between the two items. Consequently, the entire "Apsara Oil Pastels with Free Scraping Tool" package was classified under HSN 3926, attracting GST at 18% in accordance with entry no. 111 of Schedule-III.
The AAR determined that the inclusion of a free scraping tool with Apsara Oil Pastels constitutes a "mixed supply" under section 2(74) of the CGST Act, 2017, rather than a composite supply. The authority rejected the applicant's contention that the scraping tool was merely an accessory, finding that the two products were not integral to each other's function. Since the products were supplied together for a single price, section 8(b) of the CGST Act applies, requiring taxation at the higher applicable rate between the two items. Consequently, the entire "Apsara Oil Pastels with Free Scraping Tool" package was classified under HSN 3926, attracting GST at 18% in accordance with entry no. 111 of Schedule-III.
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