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...
Characterisation of supply turns on where the food is prepared: foods prepared in a retail outlet that offers dine in are treated as restaurant services (including take away) and attract GST at 5% without eligibility to claim input tax credit; identical ice cream sold in B2B transactions is treated as supply of goods (no service element) and attracts GST at 5% with input tax credit where standard GST registration and procurement rules apply. Composite supply analysis depends on the place of manufacture/retail preparation; separate manufacturing unit supplies of ice cream are goods when supplied B2B even if sold through retail outlets.
Characterisation of supply turns on where the food is prepared: foods prepared in a retail outlet that offers dine in are treated as restaurant services (including take away) and attract GST at 5% without eligibility to claim input tax credit; identical ice cream sold in B2B transactions is treated as supply of goods (no service element) and attracts GST at 5% with input tax credit where standard GST registration and procurement rules apply. Composite supply analysis depends on the place of manufacture/retail preparation; separate manufacturing unit supplies of ice cream are goods when supplied B2B even if sold through retail outlets.
Note: It is a system-generated summary and is for quick reference only.