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...
AAR holds that the Applicant, though previously issuing tax invoices from its regular registration and distributing common input tax credit (ITC) under Rule 54(1A), must, with effect from 1 April 2025, obtain registration and operate as an Input Service Distributor (ISD) to receive and distribute invoices/ITC of common input services. The AAR determines that amendments to Sections 2(61) and 20 of the CGST Act mandate transmission of common input service invoices and distribution of the corresponding ITC only through the ISD mechanism; prior practice up to March 2025 is recognised but future receipt and distribution must comply with ISD registration and prescribed ISD procedures.
AAR holds that the Applicant, though previously issuing tax invoices from its regular registration and distributing common input tax credit (ITC) under Rule 54(1A), must, with effect from 1 April 2025, obtain registration and operate as an Input Service Distributor (ISD) to receive and distribute invoices/ITC of common input services. The AAR determines that amendments to Sections 2(61) and 20 of the CGST Act mandate transmission of common input service invoices and distribution of the corresponding ITC only through the ISD mechanism; prior practice up to March 2025 is recognised but future receipt and distribution must comply with ISD registration and prescribed ISD procedures.
Note: It is a system-generated summary and is for quick reference only.