Reopening of assessment cannot rest solely on an audit party's opinion; reassessment under Section 147/148 is impermissible and power of revision shou...
Tested party selection: functional analysis identified the least complex unit as the appropriate tested party, altering the transfer pricing adjustmen...
Advance ruling maintainability and ITC eligibility are considered for construction of foundations and structural supports for heavy machinery. The Explanation to section 17 treats foundation and structural supports as part of ''plant and machinery'' (excluding land, buildings and similar civil structures), making them potentially eligible for ITC when used for outward supplies. The application lacked documentary proof on ITC eligibility, payment, availing and filings, and the works were completed before the AAR application; because advance rulings apply only to supplies being undertaken or proposed, the authority declined to rule on the merits.
Advance ruling maintainability and ITC eligibility are considered for construction of foundations and structural supports for heavy machinery. The Explanation to section 17 treats foundation and structural supports as part of ''plant and machinery'' (excluding land, buildings and similar civil structures), making them potentially eligible for ITC when used for outward supplies. The application lacked documentary proof on ITC eligibility, payment, availing and filings, and the works were completed before the AAR application; because advance rulings apply only to supplies being undertaken or proposed, the authority declined to rule on the merits.
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