Transfer pricing comparability requires functional alignment, reliable financial data, and careful review of working capital and receivables adjustmen...
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Retroactive interim-moratorium exclusion permits protective asset disclosure and preservation measures against personal guarantors pending arbitration...
The AAR declined to admit the applicant's advance ruling application, holding the questions submitted fall outside the scope of Section 97(2) of the CGST Act and thus are not amenable to an advance ruling. The Authority found the dispute concerned an internal accounting error and proposed inter-party adjustment between the applicant and its supplier, which could have been rectified via annual returns; it is not an issue of admissibility of input tax credit under clause (d) of Section 97(2). Further, under Section 95(a) the AAR has no power to issue directives binding on a third-party supplier. Accordingly, the application is not admitted.
The AAR declined to admit the applicant's advance ruling application, holding the questions submitted fall outside the scope of Section 97(2) of the CGST Act and thus are not amenable to an advance ruling. The Authority found the dispute concerned an internal accounting error and proposed inter-party adjustment between the applicant and its supplier, which could have been rectified via annual returns; it is not an issue of admissibility of input tax credit under clause (d) of Section 97(2). Further, under Section 95(a) the AAR has no power to issue directives binding on a third-party supplier. Accordingly, the application is not admitted.
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