Transfer pricing comparability requires functional alignment, reliable financial data, and careful review of working capital and receivables adjustmen...
Transfer pricing rules require benchmarking corporate guarantees and associated-enterprise advances, while invalid domestic-transaction adjustments ca...
Prospective sugar export prohibition required registered letters of credit; private contracts and export quotas created no enforceable continuation ri...
Retroactive interim-moratorium exclusion permits protective asset disclosure and preservation measures against personal guarantors pending arbitration...
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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