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...
Contingency expenses, exempt-income disallowance, and royalty benchmarking: unsupported adjustments were deleted under consistent accounting and trans...
Advance ruling jurisdiction under section 97 of the CGST Act does not extend to questions seeking guidance on the sufficiency of documentary evidence for proving that supplies to SEZ units or developers are for authorised operations. The applicant asked whether LOA or eligibility certificate evidence was enough for zero-rated treatment, or whether invoice endorsement by the Specified Officer was mandatory, but the Authority held these issues did not fall within any category listed in section 97(2), such as classification, notification applicability, time or value of supply, input tax credit, tax liability, registration, or whether an activity amounts to supply. It therefore declined to answer all three questions and left the merits of zero-rating and endorsement requirements unexamined.
Advance ruling jurisdiction under section 97 of the CGST Act does not extend to questions seeking guidance on the sufficiency of documentary evidence for proving that supplies to SEZ units or developers are for authorised operations. The applicant asked whether LOA or eligibility certificate evidence was enough for zero-rated treatment, or whether invoice endorsement by the Specified Officer was mandatory, but the Authority held these issues did not fall within any category listed in section 97(2), such as classification, notification applicability, time or value of supply, input tax credit, tax liability, registration, or whether an activity amounts to supply. It therefore declined to answer all three questions and left the merits of zero-rating and endorsement requirements unexamined.
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