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...
AAR held that the Applicant is not a "Promoter" and therefore does not fall within Notification No. 7/2019-CT(Rate); the goods received (M-sand, P-sand, blue metal, boulders, hollow bricks) from unregistered suppliers are neither notified under section 9(3) nor does the Applicant's activity fall within the scope of section 9(4). Consequently, the Applicant is not liable to discharge tax under the reverse charge mechanism on purchases of those goods from unregistered persons.
AAR held that the Applicant is not a "Promoter" and therefore does not fall within Notification No. 7/2019-CT(Rate); the goods received (M-sand, P-sand, blue metal, boulders, hollow bricks) from unregistered suppliers are neither notified under section 9(3) nor does the Applicant's activity fall within the scope of section 9(4). Consequently, the Applicant is not liable to discharge tax under the reverse charge mechanism on purchases of those goods from unregistered persons.
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