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 ruled on Input Tax Credit (ITC) eligibility for import IGST. The authority held that TR-6 challan is not a valid document for ITC availment under GST rules. Bill of entry, whether original or re-assessed, is an eligible document for ITC, subject to Section 16(4) of CGST Act time limitations. The time limit for ITC on differential IGST begins from the re-assessment date of bill of entry, provided the re-assessment is not due to fraud or wilful misstatement. The ruling emphasizes that ITC availment must be completed by the 30th November following the financial year or annual return filing, whichever is earlier.
AAR ruled on Input Tax Credit (ITC) eligibility for import IGST. The authority held that TR-6 challan is not a valid document for ITC availment under GST rules. Bill of entry, whether original or re-assessed, is an eligible document for ITC, subject to Section 16(4) of CGST Act time limitations. The time limit for ITC on differential IGST begins from the re-assessment date of bill of entry, provided the re-assessment is not due to fraud or wilful misstatement. The ruling emphasizes that ITC availment must be completed by the 30th November following the financial year or annual return filing, whichever is earlier.
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