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...
AAR rejected the advance ruling application concerning Input Tax Credit (ITC) entitlement for commercial property leasing. The ruling determined that prior investigative proceedings precluding the advance ruling application triggered Section 98(2) first proviso. Specifically, summons issued before the ruling application and taxpayer's submission of ITC details demonstrated existing proceedings on the identical issue. The investigation's commencement, even without a show cause notice, constitutes legal proceedings that prevent subsequent advance ruling. Consequently, the application was formally rejected to safeguard potential adjudication processes and prevent procedural complications in tax assessment.
AAR rejected the advance ruling application concerning Input Tax Credit (ITC) entitlement for commercial property leasing. The ruling determined that prior investigative proceedings precluding the advance ruling application triggered Section 98(2) first proviso. Specifically, summons issued before the ruling application and taxpayer's submission of ITC details demonstrated existing proceedings on the identical issue. The investigation's commencement, even without a show cause notice, constitutes legal proceedings that prevent subsequent advance ruling. Consequently, the application was formally rejected to safeguard potential adjudication processes and prevent procedural complications in tax assessment.
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