Transfer pricing comparables and operating income principles applied to software development services, with exclusions, inclusions, and tax credit ver...
Transfer pricing on performance guarantees and overdue receivables deleted where warranty obligations were embedded and working capital adjustment alr...
The AAR dismissed the applicant's advance-ruling application filed on 11-02-2025, holding it non-maintainable under the first proviso to Section 98(2) of the CGST/TNGST Acts because identical questions were already the subject of departmental proceedings commenced earlier. The Authority found the dispute-taxability arising from mismatched turnover declarations in GSTR-9 and GSTR-3B and the applicability of an exemption notification for solid-waste-management services to a municipal contract-was substantively identical to the scrutiny and recovery proceedings initiated by the assessing officer (DRC-01A dated 22-03-2024). Consequently, admission was precluded and the application was rejected.
The AAR dismissed the applicant's advance-ruling application filed on 11-02-2025, holding it non-maintainable under the first proviso to Section 98(2) of the CGST/TNGST Acts because identical questions were already the subject of departmental proceedings commenced earlier. The Authority found the dispute-taxability arising from mismatched turnover declarations in GSTR-9 and GSTR-3B and the applicability of an exemption notification for solid-waste-management services to a municipal contract-was substantively identical to the scrutiny and recovery proceedings initiated by the assessing officer (DRC-01A dated 22-03-2024). Consequently, admission was precluded and the application was rejected.
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