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 held that the Applicant's supply of pre-packaged and labelled rice (≤25 kg) for export is taxable under the IGST scheme at 5% if the Applicant opts for that route, provided the packages satisfy the notification's "pre-packaged & labelled" definition. Supplies to an exporter on a bill-to/ship-to basis and supplies to an exporter's factory are likewise taxable at 5%, but the concessional rate of 0.1% (0.05%+0.05%) under the relevant notifications is available for such supplies subject to their terms and conditions. The erstwhile restriction precluding IGST payment where concessional benefits were availed has been removed, so procuring at 0.1% does not bar exporting under IGST 5%.
AAR held that the Applicant's supply of pre-packaged and labelled rice (≤25 kg) for export is taxable under the IGST scheme at 5% if the Applicant opts for that route, provided the packages satisfy the notification's "pre-packaged & labelled" definition. Supplies to an exporter on a bill-to/ship-to basis and supplies to an exporter's factory are likewise taxable at 5%, but the concessional rate of 0.1% (0.05%+0.05%) under the relevant notifications is available for such supplies subject to their terms and conditions. The erstwhile restriction precluding IGST payment where concessional benefits were availed has been removed, so procuring at 0.1% does not bar exporting under IGST 5%.
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