Approved resolution plans extinguish unsubmitted pre-approval tax claims, preventing later recovery outside the insolvency process and preserving a cl...
Transfer pricing comparability requires functional alignment and permits working capital adjustment, while APA margins cannot govern non-covered years...
Treaty benefit, goodwill depreciation and hedging costs: export commission disallowed, while key business deductions and depreciation claims succeeded...
Undisclosed foreign asset classification requires an unexplained source; unrebutted affidavits and corroborative evidence defeated the Black Money Act...
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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