Pre-amendment reassessment limitation bars late notices under the preserved regime, invalidating consequential reassessment for affected earlier asses...
Cash-sales explanations for bank deposits require documentary reconciliation; reassessment notice survived where effective response time was available...
Functional comparability in transfer pricing prevents ad hoc arm's length adjustments where functions, assets, risks and reliable comparables are unes...
Advance ruling jurisdiction was found unavailable where the applicant sought rulings on transportation, leasing and grazing-related services as a recipient rather than as the supplier liable to discharge tax. The Authority noted that questions on determination of tax liability and notification applicability must relate to services undertaken or proposed to be undertaken by the applicant, and that liability to pay tax vests with the service supplier. On that basis, the application was not admissible. The applicant then requested withdrawal, and the Authority recorded the request and disposed of the application as withdrawn without examining the merits.
Advance ruling jurisdiction was found unavailable where the applicant sought rulings on transportation, leasing and grazing-related services as a recipient rather than as the supplier liable to discharge tax. The Authority noted that questions on determination of tax liability and notification applicability must relate to services undertaken or proposed to be undertaken by the applicant, and that liability to pay tax vests with the service supplier. On that basis, the application was not admissible. The applicant then requested withdrawal, and the Authority recorded the request and disposed of the application as withdrawn without examining the merits.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4918 
