Transfer pricing requires evidence for AMP transactions, functionally reliable comparables, and appropriate aggregation or Berry Ratio benchmarking me...
Revisionary jurisdiction cannot reopen share capital assessments where adequate inquiry supports a permissible view and no independent error is establ...
Reassessment jurisdiction fails where unverified portal information is aggregated without examining the taxpayer's explanation or relevance of entries...
Statutory sanction for delayed reassessment requires approval from the prescribed authority; approval by an inferior authority invalidates jurisdictio...
Transfer pricing margin adjustments require matching treatment of non-operating income and related costs, with comparability issues reconsidered on ev...
Preliminary-expense amortisation and MAT exempt-income adjustments prevailed, while trademark costs and managerial remuneration require fresh verifica...
Export valuation requires contemporaneous evidence; unrelated invoices cannot prove overvaluation, and dual penalties on firm and partner are impermis...
A pyjama set comprising a top and bottom sold together qualifies as a single piece for classification under the relevant notifications; a pack containing two such sets therefore comprises two pieces and cannot be treated as a single retail unit. The GST rate must be determined by sale value per piece by apportioning the pack price to each set; where the apportioned per-piece price falls below the notification threshold the lower rate applies. The subsequent amendment raising the threshold (effective 22.09.2025) is consistent with this per-piece approach. The AAR decision applying this method was upheld on the facts.
A pyjama set comprising a top and bottom sold together qualifies as a single piece for classification under the relevant notifications; a pack containing two such sets therefore comprises two pieces and cannot be treated as a single retail unit. The GST rate must be determined by sale value per piece by apportioning the pack price to each set; where the apportioned per-piece price falls below the notification threshold the lower rate applies. The subsequent amendment raising the threshold (effective 22.09.2025) is consistent with this per-piece approach. The AAR decision applying this method was upheld on the facts.
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