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 AAAR upheld the rejection of the appellant's claim regarding the classification of supply and applicable GST rate on plastic toys, as well as the entitlement to ITC on debit notes issued in 2020-21 for transactions in 2018-19. The authority found that the appellant failed to disclose all material facts as mandated under Section 104 of the CGST Act, 2017, constituting suppression and misrepresentation. Consequently, the Advance Ruling was declared void for non-compliance with statutory disclosure requirements. The appeal was dismissed, affirming that applications for advance ruling must meet the threshold under Section 98(2) and fully disclose relevant facts to enable proper adjudication.
The AAAR upheld the rejection of the appellant's claim regarding the classification of supply and applicable GST rate on plastic toys, as well as the entitlement to ITC on debit notes issued in 2020-21 for transactions in 2018-19. The authority found that the appellant failed to disclose all material facts as mandated under Section 104 of the CGST Act, 2017, constituting suppression and misrepresentation. Consequently, the Advance Ruling was declared void for non-compliance with statutory disclosure requirements. The appeal was dismissed, affirming that applications for advance ruling must meet the threshold under Section 98(2) and fully disclose relevant facts to enable proper adjudication.
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