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 quit rent paid to the State via the Forest Department for leased agricultural land constitutes consideration for a leasing service and is classifiable under SAC 9986 (renting or leasing of vacant land), not under SAC 9972 (real estate services). Consequently, the lease rent collected by the Government for agricultural land through the Forest Department falls within the exemption scope of Entry No. 54 of Notification No. 12/2017-Central Tax (Rate) and is exempt from GST. The ruling concludes the payment is a taxable service by classification but, as applicable, is relieved from tax liability by the specified exemption entry.
AAR holds that the quit rent paid to the State via the Forest Department for leased agricultural land constitutes consideration for a leasing service and is classifiable under SAC 9986 (renting or leasing of vacant land), not under SAC 9972 (real estate services). Consequently, the lease rent collected by the Government for agricultural land through the Forest Department falls within the exemption scope of Entry No. 54 of Notification No. 12/2017-Central Tax (Rate) and is exempt from GST. The ruling concludes the payment is a taxable service by classification but, as applicable, is relieved from tax liability by the specified exemption entry.
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