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 supplies of frozen poultry (CTH 0207) sold to institutional or industrial consumers bearing the declaration "not for retail sale," whether procured directly from the manufacturer, an importer, or a wholesale dealer, constitute supplies for consumption by qualifying institutions and, where supported by a verifiable documentary trail and exclusive non-resale use, fall outside the GST concept of "pre-packaged and labelled" goods and thus qualify for the notified exemption. The ruling is strictly conditional: failure to comply with the statutory declaration, documentary evidence, or diversion to non-institutional/retail use means the goods retain the character of pre-packaged labeled frozen meat and attract GST at 5% under the relevant rate notification.
AAR held that supplies of frozen poultry (CTH 0207) sold to institutional or industrial consumers bearing the declaration "not for retail sale," whether procured directly from the manufacturer, an importer, or a wholesale dealer, constitute supplies for consumption by qualifying institutions and, where supported by a verifiable documentary trail and exclusive non-resale use, fall outside the GST concept of "pre-packaged and labelled" goods and thus qualify for the notified exemption. The ruling is strictly conditional: failure to comply with the statutory declaration, documentary evidence, or diversion to non-institutional/retail use means the goods retain the character of pre-packaged labeled frozen meat and attract GST at 5% under the relevant rate notification.
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