Additional evidence in departmental appeals may include show-cause-notice material without introducing a new case where it merely corroborates existin...
Reasoned rectification orders require consideration of expenditure disclosed in income-tax returns, preventing revision based on incomplete income com...
Modified returns after business reorganisations cannot trigger fresh scrutiny once the original assessment was complete, invalidating related transfer...
Third-party loose sheets require reliable nexus before supporting unexplained expenditure additions; presumptions do not establish payer identity or o...
TNMM comparability using audited accounts and working-capital adjustments can eliminate unwarranted transfer-pricing additions where verified margins ...
Gross-profit additions on disputed purchases require reasoned appellate determination; disclosed claims alone do not support inaccurate-particulars pe...
Limitation after transfer-pricing remand: fresh TPO reference did not extend the assessment deadline, rendering the consequential assessment time-barr...
Interim judicial restraint on tax deduction prevents default, while supporting reasonable cause and penalty deletion for foreign-leg LFC reimbursement...
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 
TaxTMI 
of 4896 
