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...
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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