Transfer pricing comparables and adjustments: Tribunal revisits loss-maker status, segmental comparability, working capital relief, and risk allocatio...
Business expenditure disallowance failed where commission, related-party salary and promotion payments were supported by records and inquiry was inade...
GST assessment orders concerning short payment of tax and alleged non-payment on seigniorage fees under reverse charge mechanism were remitted for fresh adjudication. On the short-reported turnover issue, the impugned orders were treated as an addendum to the show cause notices, and the taxpayer was required to deposit 25% of the disputed tax and file separate replies with supporting documents before fresh merits-based orders were passed. On the seigniorage-fee issue, substantive taxability was not decided; instead, the matter was deferred, a 10% deposit and replies were required, and separate orders were directed only after the Supreme Court resolves the reverse charge taxability question, leaving that controversy open.
GST assessment orders concerning short payment of tax and alleged non-payment on seigniorage fees under reverse charge mechanism were remitted for fresh adjudication. On the short-reported turnover issue, the impugned orders were treated as an addendum to the show cause notices, and the taxpayer was required to deposit 25% of the disputed tax and file separate replies with supporting documents before fresh merits-based orders were passed. On the seigniorage-fee issue, substantive taxability was not decided; instead, the matter was deferred, a 10% deposit and replies were required, and separate orders were directed only after the Supreme Court resolves the reverse charge taxability question, leaving that controversy open.
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