Reasoned rectification orders require consideration of expenditure disclosed in income-tax returns, preventing revision based on incomplete income com...
Modified returns after business reorganisations cannot trigger fresh scrutiny once the original assessment was complete, invalidating related transfer...
Third-party loose sheets require reliable nexus before supporting unexplained expenditure additions; presumptions do not establish payer identity or o...
TNMM comparability using audited accounts and working-capital adjustments can eliminate unwarranted transfer-pricing additions where verified margins ...
Gross-profit additions on disputed purchases require reasoned appellate determination; disclosed claims alone do not support inaccurate-particulars pe...
Limitation after transfer-pricing remand: fresh TPO reference did not extend the assessment deadline, rendering the consequential assessment time-barr...
Interim judicial restraint on tax deduction prevents default, while supporting reasonable cause and penalty deletion for foreign-leg LFC reimbursement...
Palmolein classification defeated the crude-oil concession; material misdeclaration sustained recovery and confiscation, while separate false-document...
The AAR held that the applicant's supply of planning, estimates and DTP services for building works to a state R&B department do not attract GST exemption under the entries linked to Article 243G/243W unless the services bear a direct and proximate relationship to a function entrusted to a Panchayat or Municipality. Exemption notifications are to be strictly construed and the onus lies on the taxpayer to demonstrate applicability. The Authority concluded the services provided for listed public buildings and facilities (including ITI, bird sanctuary, government schools and hostels, rehabilitation homes, animal husbandry centres, storm water drains, fish farm facilities and seed godown) do not qualify as activities "in relation to" Panchayat/Municipality functions.
The AAR held that the applicant's supply of planning, estimates and DTP services for building works to a state R&B department do not attract GST exemption under the entries linked to Article 243G/243W unless the services bear a direct and proximate relationship to a function entrusted to a Panchayat or Municipality. Exemption notifications are to be strictly construed and the onus lies on the taxpayer to demonstrate applicability. The Authority concluded the services provided for listed public buildings and facilities (including ITI, bird sanctuary, government schools and hostels, rehabilitation homes, animal husbandry centres, storm water drains, fish farm facilities and seed godown) do not qualify as activities "in relation to" Panchayat/Municipality functions.
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