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...
The circular prescribes the workflow for departmental appeals, cross-objections and replies before the GST Appellate Tribunal and its Principal Bench. It requires zone-wise scrutiny of adverse appellate orders by a committee, opinion by the relevant Joint Commissioner or Additional Commissioner within fixed timelines, and Commissioner authorization before filing. Draft appeal memoranda must be prepared in English at the originating office level, vetted by the State Representative, and filed online with defect rectification ensured. It also sets a mechanism for dropping cases, applies the same procedure where taxpayers file appeals, and assigns representative authority subject to monetary limits, while preserving filing where substantial questions of law arise and superseding earlier instructions.
The circular prescribes the workflow for departmental appeals, cross-objections and replies before the GST Appellate Tribunal and its Principal Bench. It requires zone-wise scrutiny of adverse appellate orders by a committee, opinion by the relevant Joint Commissioner or Additional Commissioner within fixed timelines, and Commissioner authorization before filing. Draft appeal memoranda must be prepared in English at the originating office level, vetted by the State Representative, and filed online with defect rectification ensured. It also sets a mechanism for dropping cases, applies the same procedure where taxpayers file appeals, and assigns representative authority subject to monetary limits, while preserving filing where substantial questions of law arise and superseding earlier instructions.
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