Pure-agent exclusion fails where hotel booking facilitators receive third-party services themselves, making entire customer consideration taxable as r...
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...
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Biodegradable bag classification depends on constituent material: bags made of polymer or compostable plastics fall under Chapter 39, while bags made of paper fall under Chapter 48. The Authority declined to determine actual biodegradability or compostability, treating that as a scientific question outside its jurisdiction under Section 97(2). Entry No. 319 of Schedule I grants a 5% concessional rate for paper sacks/bags and biodegradable bags only if the goods are in fact biodegradable; if that condition is not met, the concessional entry does not apply and the general rate under the applicable Chapter 39 classification governs.
Biodegradable bag classification depends on constituent material: bags made of polymer or compostable plastics fall under Chapter 39, while bags made of paper fall under Chapter 48. The Authority declined to determine actual biodegradability or compostability, treating that as a scientific question outside its jurisdiction under Section 97(2). Entry No. 319 of Schedule I grants a 5% concessional rate for paper sacks/bags and biodegradable bags only if the goods are in fact biodegradable; if that condition is not met, the concessional entry does not apply and the general rate under the applicable Chapter 39 classification governs.
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