Pre-amendment reassessment limitation bars late notices under the preserved regime, invalidating consequential reassessment for affected earlier asses...
Cash-sales explanations for bank deposits require documentary reconciliation; reassessment notice survived where effective response time was available...
Functional comparability in transfer pricing prevents ad hoc arm's length adjustments where functions, assets, risks and reliable comparables are unes...
Contingency expenses, exempt-income disallowance, and royalty benchmarking: unsupported adjustments were deleted under consistent accounting and trans...
AAR held that third-party organization marketing exempted yoga courses cannot claim GST exemption on yoga course fees collected on behalf of yoga institutions. While Rule 33 CGST Rules 2017 permits exclusion of amounts collected by pure agents, applicant failed to provide documentary evidence establishing compliance with mandatory conditions including contractual arrangements authorizing expense incurrence, separate invoice indication, and strict cost pass-through without markup. Without demonstrating pure agent status within Rule 33 parameters, GST exemption on yoga course fee component was denied. Organization remains liable for GST on entire transaction value including collected fees despite underlying yoga courses being exempt.
AAR held that third-party organization marketing exempted yoga courses cannot claim GST exemption on yoga course fees collected on behalf of yoga institutions. While Rule 33 CGST Rules 2017 permits exclusion of amounts collected by pure agents, applicant failed to provide documentary evidence establishing compliance with mandatory conditions including contractual arrangements authorizing expense incurrence, separate invoice indication, and strict cost pass-through without markup. Without demonstrating pure agent status within Rule 33 parameters, GST exemption on yoga course fee component was denied. Organization remains liable for GST on entire transaction value including collected fees despite underlying yoga courses being exempt.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4918 
