Trademark depreciation and section 14A adjustments: ITAT applies consistency, independent book-profit computation, and no disallowance without exempt ...
Advance rulings under Section 95(a) are prospective; where all contractual acts, possession and payment were completed before filing, the transaction is not a supply "being undertaken or proposed" and therefore falls outside the AAR's permissible scope. The authority found that the assignment of leasehold rights and related charges were fully executed before the application, so questions on taxability of land development charges and eligibility of input tax credit could not be determined by advance ruling. Consequence: the application was held not maintainable and the AAR declined to decide the substantive tax issues.
Advance rulings under Section 95(a) are prospective; where all contractual acts, possession and payment were completed before filing, the transaction is not a supply "being undertaken or proposed" and therefore falls outside the AAR's permissible scope. The authority found that the assignment of leasehold rights and related charges were fully executed before the application, so questions on taxability of land development charges and eligibility of input tax credit could not be determined by advance ruling. Consequence: the application was held not maintainable and the AAR declined to decide the substantive tax issues.
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