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 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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