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 determined that the advance ruling application by the contractor regarding GST rate reimbursement was inadmissible. The ruling authority found the tax liability assessment question does not align with Section 97(2) of CGST Act, 2017. Due to the applicant's failure to respond to official notices and the nature of the query falling outside statutory provisions, no substantive ruling was issued. The application was effectively dismissed without addressing the underlying GST rate dispute between 5% and 12% for the works contract.
AAR determined that the advance ruling application by the contractor regarding GST rate reimbursement was inadmissible. The ruling authority found the tax liability assessment question does not align with Section 97(2) of CGST Act, 2017. Due to the applicant's failure to respond to official notices and the nature of the query falling outside statutory provisions, no substantive ruling was issued. The application was effectively dismissed without addressing the underlying GST rate dispute between 5% and 12% for the works contract.
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