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...
AAAR affirmed that the product is classifiable under tariff item 38089340 as a plant growth regulator and attracts integrated tax at 18% (9% CGST + 9% SGST) under the referenced notification. The authority held that the appellant bears the onus of full disclosure in an advance ruling application and cannot rely on proprietary nondisclosure by its supplier to avoid that duty; alleged non-party status to prior disputes was immaterial, and submitted laboratory certificates undermined that claim. Challenges that the product is a fertilizer or a vegetable-origin enzyme were rejected for lack of probative evidence. The appellant's appeal is dismissed.
AAAR affirmed that the product is classifiable under tariff item 38089340 as a plant growth regulator and attracts integrated tax at 18% (9% CGST + 9% SGST) under the referenced notification. The authority held that the appellant bears the onus of full disclosure in an advance ruling application and cannot rely on proprietary nondisclosure by its supplier to avoid that duty; alleged non-party status to prior disputes was immaterial, and submitted laboratory certificates undermined that claim. Challenges that the product is a fertilizer or a vegetable-origin enzyme were rejected for lack of probative evidence. The appellant's appeal is dismissed.
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