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 classified plastic Rooter Trainer Cups used for plant propagation under CTH 3926 90 99 rather than HSN 8201 90 00. The Authority determined that since the product is manufactured from plastic, it falls under Chapter 39 "Plastics and Articles thereof" of the Customs Tariff. The cups did not qualify under any specific 4-digit headings within Chapter 39, thus falling under the residual heading 3926 "Other Articles of Plastics" and subsequently under sub-heading 3926 90 99. The Authority rejected classification under Chapter 8201 as the product neither qualifies as agricultural implements nor meets the manually operated or animal-driven criteria for exemption. The applicable GST rate is 18% (9% CGST + 9% SGST) under Schedule III, Serial Number 111 of the relevant notification.
The AAR classified plastic Rooter Trainer Cups used for plant propagation under CTH 3926 90 99 rather than HSN 8201 90 00. The Authority determined that since the product is manufactured from plastic, it falls under Chapter 39 "Plastics and Articles thereof" of the Customs Tariff. The cups did not qualify under any specific 4-digit headings within Chapter 39, thus falling under the residual heading 3926 "Other Articles of Plastics" and subsequently under sub-heading 3926 90 99. The Authority rejected classification under Chapter 8201 as the product neither qualifies as agricultural implements nor meets the manually operated or animal-driven criteria for exemption. The applicable GST rate is 18% (9% CGST + 9% SGST) under Schedule III, Serial Number 111 of the relevant notification.
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