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 held that the applicant is ineligible for exemption under serial no. 66(b)(i) & (ii) of notification No. 12/2017-CT (Rate) for transportation and catering services provided directly to students, as the consideration was received from students and not from the educational institution. Consequently, the services are not deemed to be provided to the school, failing the primary condition for exemption. The authority further declined to address the question of refund of tax paid on such services in earlier years, as it falls outside the scope of subsection 97(2). Therefore, the applicant cannot claim exemption or refund under the specified notification for the impugned services.
The AAR held that the applicant is ineligible for exemption under serial no. 66(b)(i) & (ii) of notification No. 12/2017-CT (Rate) for transportation and catering services provided directly to students, as the consideration was received from students and not from the educational institution. Consequently, the services are not deemed to be provided to the school, failing the primary condition for exemption. The authority further declined to address the question of refund of tax paid on such services in earlier years, as it falls outside the scope of subsection 97(2). Therefore, the applicant cannot claim exemption or refund under the specified notification for the impugned services.
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