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 AAR denied the rectification application, holding that rectification under Section 102 is permissible only for errors apparent on the face of the record and that no such error existed. The applicant sought insertion of a provision characterising body-building activity performed on a chassis owned by an unregistered customer as supply of services under SI No. 26(iv) / heading 998881 read with Schedule II; the AAR found the requested text redundant because the substance of that contention had already been addressed in the advance ruling. Consequently, the rectification petition was rejected as untenable under Section 98(2) of the CGST/TNGST Act, 2017.
The AAR denied the rectification application, holding that rectification under Section 102 is permissible only for errors apparent on the face of the record and that no such error existed. The applicant sought insertion of a provision characterising body-building activity performed on a chassis owned by an unregistered customer as supply of services under SI No. 26(iv) / heading 998881 read with Schedule II; the AAR found the requested text redundant because the substance of that contention had already been addressed in the advance ruling. Consequently, the rectification petition was rejected as untenable under Section 98(2) of the CGST/TNGST Act, 2017.
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