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...
AAAR held that transportation services provided by appellant to school students and staff do not qualify for GST exemption under Serial No.66 of Notification 12/2017-Central Tax (Rate). The contractual arrangements demonstrated that appellant directly supplied transportation services to students/staff with fees collected from parents, while educational institutions neither provided nor received services in the transaction. The exemption notification requires services to be provided by or to educational institutions, which was not established. AAAR emphasized strict interpretation of exemption notifications with burden of proof on claimant. The ruling distinguished previous AAR decisions as non-binding and factually dissimilar, concluding exemption unavailable under present circumstances.
AAAR held that transportation services provided by appellant to school students and staff do not qualify for GST exemption under Serial No.66 of Notification 12/2017-Central Tax (Rate). The contractual arrangements demonstrated that appellant directly supplied transportation services to students/staff with fees collected from parents, while educational institutions neither provided nor received services in the transaction. The exemption notification requires services to be provided by or to educational institutions, which was not established. AAAR emphasized strict interpretation of exemption notifications with burden of proof on claimant. The ruling distinguished previous AAR decisions as non-binding and factually dissimilar, concluding exemption unavailable under present circumstances.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4794
Join Channel
TaxTMI 
