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 provision of rooms to the respondent (a central bank) constitutes "hotel accommodation" for GST purposes where the room tariff is below Rs.7,500 per day per unit, and thus is a taxable supply under GST. The Authority distinguished "hotel accommodation service" (SAC 9963) from "renting service" (SAC 9972), finding them to fall under separate entries of the rate notification (serial no. 7(i)/(vi) and serial no. 15(7) respectively). The AAR further held that the GST characterization of hotel accommodation is independent of the Income Tax Act and must be governed solely by the GST law and applicable rate notifications.
The AAR held that the applicant's provision of rooms to the respondent (a central bank) constitutes "hotel accommodation" for GST purposes where the room tariff is below Rs.7,500 per day per unit, and thus is a taxable supply under GST. The Authority distinguished "hotel accommodation service" (SAC 9963) from "renting service" (SAC 9972), finding them to fall under separate entries of the rate notification (serial no. 7(i)/(vi) and serial no. 15(7) respectively). The AAR further held that the GST characterization of hotel accommodation is independent of the Income Tax Act and must be governed solely by the GST law and applicable rate notifications.
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