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 appellant is not entitled to avoid reversal of input tax credit (ITC) on common inputs and input services relating to mutual fund subscription and redemption, holding that the deeming provision in section 17(3) incorporates "transactions in securities" into the value of exempt supplies for ITC reversal. The authority rejected the contention that "securities" exclusion from goods/services removes them from exempt/non-taxable supply treatment and construed the Rule reference to "sale value" consistently with "transactions in securities," encompassing redemptions. The AAAR also found no substantiation that subscription/redemption activities were in the course or furtherance of the appellant's business. The appeal is dismissed.
AAAR affirmed that the appellant is not entitled to avoid reversal of input tax credit (ITC) on common inputs and input services relating to mutual fund subscription and redemption, holding that the deeming provision in section 17(3) incorporates "transactions in securities" into the value of exempt supplies for ITC reversal. The authority rejected the contention that "securities" exclusion from goods/services removes them from exempt/non-taxable supply treatment and construed the Rule reference to "sale value" consistently with "transactions in securities," encompassing redemptions. The AAAR also found no substantiation that subscription/redemption activities were in the course or furtherance of the appellant's business. The appeal is dismissed.
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