Patent-settlement expenditure treated as commercially expedient revenue outlay, with foreign-law restrictions inapplicable before the prospective amen...
International transaction benchmarking restricts transfer pricing adjustments to associated-enterprise dealings, while functional comparability govern...
Joint development agreements defer taxable transfer where possession lacks part performance, while completed flats determine consideration and exempti...
Passenger baggage re-export requires true declaration and cannot be granted indirectly through discretionary redemption of undeclared prohibited goods...
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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