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 particulate matter permits are tradable goods, not securities, and are classifiable under HSN Heading 4907 (residuary code 4970 00 90). Applying ejusdem generis, the Authority rejected treating PM-permits as akin to bonds, stocks or debentures. The permits confer transferable economic benefits, have market value, are auctioned on the designated trading platform and may be sold for profit; accordingly proceeds constitute business income and sales are in the course or furtherance of business. Restrictions on transferability or expiry do not alter their character as goods. The applicable GST rate on trading of PM-permits is 12%.
The AAR held that particulate matter permits are tradable goods, not securities, and are classifiable under HSN Heading 4907 (residuary code 4970 00 90). Applying ejusdem generis, the Authority rejected treating PM-permits as akin to bonds, stocks or debentures. The permits confer transferable economic benefits, have market value, are auctioned on the designated trading platform and may be sold for profit; accordingly proceeds constitute business income and sales are in the course or furtherance of business. Restrictions on transferability or expiry do not alter their character as goods. The applicable GST rate on trading of PM-permits is 12%.
Note: It is a system-generated summary and is for quick reference only.
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