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...
Jurisdiction in GST proceedings is determined as on the date the power is invoked, so a valid action or proceeding taken by the transferor jurisdictional authority before migration or transfer of a taxable person remains valid. The transferee jurisdictional authority must then take over, give effect to, and continue the matter from that stage, including consequential proceedings and representation in appeals, while the transferor authority cannot initiate fresh action after the transfer and must pass any new issue to the transferee authority. The Goa GST circular applies the corresponding CBIC clarification mutatis mutandis under the Goa GST Act.
Jurisdiction in GST proceedings is determined as on the date the power is invoked, so a valid action or proceeding taken by the transferor jurisdictional authority before migration or transfer of a taxable person remains valid. The transferee jurisdictional authority must then take over, give effect to, and continue the matter from that stage, including consequential proceedings and representation in appeals, while the transferor authority cannot initiate fresh action after the transfer and must pass any new issue to the transferee authority. The Goa GST circular applies the corresponding CBIC clarification mutatis mutandis under the Goa GST Act.
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