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 held that the Applicant is not entitled to input tax credit for GST paid on fire-fighting systems and public-health equipment installed as part of a new factory. The installations were characterized as permanently affixed to immovable property and thus not "plant and machinery," bringing the supply within the embargoes of s.17(5)(c) and, alternatively, s.17(5)(d) of the CGST/TNGST Act, 2017; GST attributable to the composite works contract is therefore non-creditable. Because ITC denial on the specific contract is dispositive, the AAR declined to adjudicate the ancillary question on the timing for availing ITC against supplier "advance component" invoices.
The AAR held that the Applicant is not entitled to input tax credit for GST paid on fire-fighting systems and public-health equipment installed as part of a new factory. The installations were characterized as permanently affixed to immovable property and thus not "plant and machinery," bringing the supply within the embargoes of s.17(5)(c) and, alternatively, s.17(5)(d) of the CGST/TNGST Act, 2017; GST attributable to the composite works contract is therefore non-creditable. Because ITC denial on the specific contract is dispositive, the AAR declined to adjudicate the ancillary question on the timing for availing ITC against supplier "advance component" invoices.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4798
Join Channel
TaxTMI 
