Transfer pricing comparables and adjustments: Tribunal revisits loss-maker status, segmental comparability, working capital relief, and risk allocatio...
Business expenditure disallowance failed where commission, related-party salary and promotion payments were supported by records and inquiry was inade...
AAAR set aside the advance ruling regarding classification of tapioca flour and remnants obtained from crushing dried tapioca roots under GST provisions. The appellant-trader failed to provide sufficient documentary evidence from manufacturers regarding the exact manufacturing process, which is crucial for proper tariff classification under Chapter 11 versus Chapter 23. The Authority found that products in Chapter 11 are primarily for food industry use while Chapter 23 covers milling residues for animal feed. Since the appellant could not substantiate claims about the manufacturing process and the lower authority failed to consider complete facts, principles of natural justice were violated. The matter was remanded to the original Authority for fresh consideration with proper opportunity for the appellant to present evidence and be heard in person before determining correct classification and tax liability.
AAAR set aside the advance ruling regarding classification of tapioca flour and remnants obtained from crushing dried tapioca roots under GST provisions. The appellant-trader failed to provide sufficient documentary evidence from manufacturers regarding the exact manufacturing process, which is crucial for proper tariff classification under Chapter 11 versus Chapter 23. The Authority found that products in Chapter 11 are primarily for food industry use while Chapter 23 covers milling residues for animal feed. Since the appellant could not substantiate claims about the manufacturing process and the lower authority failed to consider complete facts, principles of natural justice were violated. The matter was remanded to the original Authority for fresh consideration with proper opportunity for the appellant to present evidence and be heard in person before determining correct classification and tax liability.
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