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 transaction constitutes a composite "works contract" under s.2(119) CGST, permitting ITC only on the structural steel/plant-and-machinery component as delineated in the contract Cost Abstract/Bill of Quantities, and not on civil or sheeting components. Cranes and HVAC were characterised as plant and machinery, supporting the secondary steel's eligibility. Concerning advances, the AAR ruled that time-of-supply principles in s.13(2) render receipt of advance as deemed receipt, and therefore ITC on supplier invoices for advance payments may be availed subject to the temporal limitation in s.16(4) - i.e., before 30 November following the FY or on filing the annual return, whichever is earlier.
The AAR held that the applicant's transaction constitutes a composite "works contract" under s.2(119) CGST, permitting ITC only on the structural steel/plant-and-machinery component as delineated in the contract Cost Abstract/Bill of Quantities, and not on civil or sheeting components. Cranes and HVAC were characterised as plant and machinery, supporting the secondary steel's eligibility. Concerning advances, the AAR ruled that time-of-supply principles in s.13(2) render receipt of advance as deemed receipt, and therefore ITC on supplier invoices for advance payments may be availed subject to the temporal limitation in s.16(4) - i.e., before 30 November following the FY or on filing the annual return, whichever is earlier.
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