Revenue neutrality in domestic related-party loans can require deletion of interest transfer pricing adjustments after domestic-transaction verificati...
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.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4790
Join Channel
TaxTMI 
