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 on GST applicability for electricity transmission utility services. The key findings are: shifting/raising transmission towers at third-party request constitutes a taxable supply under service category "agreeing to do an act" (HSN 999792). The services are not transmission-related but infrastructure modification services. The supply is chargeable at 18% GST under Section 7 of CGST Act, 2017. Time of supply follows Section 13 of CGST Act. The value of supply is determined under Section 15 of CGST Act. Input tax credit availability depends on whether the construction relates to plant and machinery or immovable property. The ruling clarifies that infrastructure modification services for dedicated consumers are taxable commercial transactions.
The AAR ruled on GST applicability for electricity transmission utility services. The key findings are: shifting/raising transmission towers at third-party request constitutes a taxable supply under service category "agreeing to do an act" (HSN 999792). The services are not transmission-related but infrastructure modification services. The supply is chargeable at 18% GST under Section 7 of CGST Act, 2017. Time of supply follows Section 13 of CGST Act. The value of supply is determined under Section 15 of CGST Act. Input tax credit availability depends on whether the construction relates to plant and machinery or immovable property. The ruling clarifies that infrastructure modification services for dedicated consumers are taxable commercial transactions.
Note: It is a system-generated summary and is for quick reference only.