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 holds that the applicant's material, being the residue ("thippi") generated in Stage-I cassava starch manufacture and sold for further processing/animal feed, is not cassava flour or cassava starch and is classifiable as a residue/waste under Chapter 23 (tariff item 2303 1000). The material is marketable but arises as a by-product/residue of a starch production process and therefore falls outside Chapter 11 classification. The applicant is not entitled to the exemption under Notification No. 02/2017-CT(Rate) in respect of tariff item 1106, and the supplies attract GST; accordingly the applicant must obtain registration and discharge applicable tax.
The AAR holds that the applicant's material, being the residue ("thippi") generated in Stage-I cassava starch manufacture and sold for further processing/animal feed, is not cassava flour or cassava starch and is classifiable as a residue/waste under Chapter 23 (tariff item 2303 1000). The material is marketable but arises as a by-product/residue of a starch production process and therefore falls outside Chapter 11 classification. The applicant is not entitled to the exemption under Notification No. 02/2017-CT(Rate) in respect of tariff item 1106, and the supplies attract GST; accordingly the applicant must obtain registration and discharge applicable tax.
Note: It is a system-generated summary and is for quick reference only.