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's hotel will not qualify as a "specified premises" for FY 2025-26 because, for FY 2024-25, the per-room combined charge under the American or Continental Plan did not exceed Rs.7,500 per day; accordingly restaurant services to walk-in guests remain taxable under the ordinary rate applicable to standalone restaurant supply. The Authority further held that if in any subsequent financial year a unit of accommodation is charged at above Rs.7,500 (inclusive of food under the applicable plan, even if itemised), the premises will be treated as "specified premises" for the next financial year and restaurant services to walk-in guests will attract 9% CGST + 9% SGST.
The AAR held that the applicant's hotel will not qualify as a "specified premises" for FY 2025-26 because, for FY 2024-25, the per-room combined charge under the American or Continental Plan did not exceed Rs.7,500 per day; accordingly restaurant services to walk-in guests remain taxable under the ordinary rate applicable to standalone restaurant supply. The Authority further held that if in any subsequent financial year a unit of accommodation is charged at above Rs.7,500 (inclusive of food under the applicable plan, even if itemised), the premises will be treated as "specified premises" for the next financial year and restaurant services to walk-in guests will attract 9% CGST + 9% SGST.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4801
Join Channel
TaxTMI 
