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...
Contractual supply of food to corporate clients was held to be a supply of service, not restaurant service, because the provider was engaged in menu finalisation, hygiene and quality oversight, delivery coordination, and personnel deployment under service agreements. The activity did not involve its own restaurant, eating joint, mess or canteen premises, and did not fall within outdoor catering or hotel accommodation. It was classified under SAC 996337 as a residual food and beverage service, outside entries 7(i) to 7(v) of Notification No. 11/2017-Central Tax (Rate), and therefore taxable under entry 7(vi) at 18% GST. The advance ruling was affirmed.
Contractual supply of food to corporate clients was held to be a supply of service, not restaurant service, because the provider was engaged in menu finalisation, hygiene and quality oversight, delivery coordination, and personnel deployment under service agreements. The activity did not involve its own restaurant, eating joint, mess or canteen premises, and did not fall within outdoor catering or hotel accommodation. It was classified under SAC 996337 as a residual food and beverage service, outside entries 7(i) to 7(v) of Notification No. 11/2017-Central Tax (Rate), and therefore taxable under entry 7(vi) at 18% GST. The advance ruling was affirmed.
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