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...
The AAR ruled that the applicant is not eligible to avail Input Tax Credit (ITC) on tax paid for inputs and input services related to mutual fund subscription and redemption activities. The Authority rejected the applicant's contention that redemption of mutual funds differs from sale of securities, clarifying that redemption constitutes a sale transaction regardless of nomenclature, as it involves cessation of ownership by the unit holder. Consequently, the applicant must reverse ITC on common inputs and input services used for mutual fund subscription and redemption activities in accordance with Section 17(2). The applicant's argument regarding lack of statutory machinery provisions to calculate exempt supply value was also dismissed.
The AAR ruled that the applicant is not eligible to avail Input Tax Credit (ITC) on tax paid for inputs and input services related to mutual fund subscription and redemption activities. The Authority rejected the applicant's contention that redemption of mutual funds differs from sale of securities, clarifying that redemption constitutes a sale transaction regardless of nomenclature, as it involves cessation of ownership by the unit holder. Consequently, the applicant must reverse ITC on common inputs and input services used for mutual fund subscription and redemption activities in accordance with Section 17(2). The applicant's argument regarding lack of statutory machinery provisions to calculate exempt supply value was also dismissed.
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