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 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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