Transfer pricing comparability: one support-services company accepted, government-owned and facility-management comparables excluded, forex loss claim...
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The AAR dismissed the applicant's advance ruling application as inadmissible and rejected it on grounds that an investigation and antecedent show-cause proceedings by the revenue investigation unit were pending on the same questions, and the applicant failed to disclose issuance of the SCN, amounting to suppression of material facts. Under the statutory scheme governing advance rulings, the Authority will not admit matters already the subject of proceedings in the applicant's case; non-disclosure demonstrated lack of candour and disentitled the applicant to relief. Consequently, the application regarding levy of output tax and entitlement to input tax credit for outward transportation services was refused.
The AAR dismissed the applicant's advance ruling application as inadmissible and rejected it on grounds that an investigation and antecedent show-cause proceedings by the revenue investigation unit were pending on the same questions, and the applicant failed to disclose issuance of the SCN, amounting to suppression of material facts. Under the statutory scheme governing advance rulings, the Authority will not admit matters already the subject of proceedings in the applicant's case; non-disclosure demonstrated lack of candour and disentitled the applicant to relief. Consequently, the application regarding levy of output tax and entitlement to input tax credit for outward transportation services was refused.
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